2001 Oct. 18 L. Robinson Reply to H.moores Letters of 30 Aug 2001 and 11 Oct 2001

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  • 8/7/2019 2001 Oct. 18 L. Robinson Reply to H.moores Letters of 30 Aug 2001 and 11 Oct 2001

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    LEONARD M. ROBINSON

    Attorneyat Law1/;05 5W 37"' Street

    Topeka. KS 66611-2810

    UCENSEDlN

    KANSAS AND COLORADO

    October 18, 200 I

    Mr. Hany MooreAssistant Director, Court ServicesShawnee County Courthouse200 SE1', Suite 104Topeka, Kansas 66603-3961

    RE: Your lettersono August200I and II October200I960217

    DearHany:

    BusinessFAX

    Residence

    (785) 267-5063(785) 267-2652(785) 862-2475

    The first thing I want to do is answer your question in regard to Claudine when she picked upRikki back in December of 2000 and their whereabouts. My client informs me that Rikki and her werein Kansas other than an ov.emight stay on December 24,2000 at her Mother's in Texas.

    I also checked with my client in regards to the pictures showing her bloodied and beaten. Sheindicates that the Pottawatomie County Sheriffs Department has pictures and the negatives of thosepictures that show her physical condition and that it would be obvious that they were not altered. Ihave tried to get away from arguing about whether Hal Richardson raped Claudine or not in that thepictures obviously show that violence was done toward her whether there was a rape or simply batterymakes linIe difference in regard to whether he is violent or not.

    . It appears at this time that we will not be able to get a change of custody, however, it wouldseem appropriate that Claudine and Rikki have unsupervised visitation and that the visitation beconsistent with the Shawnee County Guidelines.

    Claudine, back in December of 2000, did not bring Rikki back and it was due to her fearswhich there was physical evidence of abuse to both herself and to Rikki. We don't want to argue thatissue at this point However, it should be taken into consideration in regard to at least the visitationissue. Claudine could have taken Rikki at any time during the last many months of visitation and hasnot done so nor does she intend to do so. She should not be punished nor should Rikki be punished

  • 8/7/2019 2001 Oct. 18 L. Robinson Reply to H.moores Letters of 30 Aug 2001 and 11 Oct 2001

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    Mr. Harry MooreOctober 18, 200 1Page Two

    along with her by continuing such a restriction on the visitation and thus I am asking both you and Mr.Hoffinan on behalf of his client to at the very least agree to commencing unsupervised guidelinevisitation.

    Please make note of my new address and telephone number.

    Sincerely,

    LMR:clsCc: Ms. Claudine Dombrowski

    Donald Hoffinan