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8/8/2019 5-21-1999 CINC Barton County to Keep Minor Child Safe From Abusive Father Dom Brow Ski
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A P ~ ~ 3 0 - 9 9F R I 0 4 : 0 2 P HR I L I N G B U R K H E A D N I T G E R
. .'~
F A X N O . 7 8 5 8 4 3 0 1 6 1 PCOpy OF THE ORIGINALFILED IN CLERK OFDISTRICT COURT OFFICE~~~~ON fQ Ytf"l _AS
IN THE DISTRICT COURT OF BARTON COUNTY, KANSAS
In tbe Interest of
RlKKI DOMBROWSKIajuvenile under the age of 18 years, to-wit: 12.12-94
PurSUanl to K.S.A.Chapter 38
)))))
PETITION TO DECLARE THE MINOR CIIILD
A CHILD IN NEED OF CARE
COMES NOW Claudine Dombrowski, the natural mother ofRikki Dombrowski, to
petition the court to declan: Rikki Dombrowski a Child in Need of Care. In support of her,
Petition, she states:
1. Ms. Claudine Dombrowski and Mr. Halleck Richardson are the parents of the ._~
above mentioned minor child, Rikki Dombrowski, age four (4), d/olb December
12, 1994.
2. The minor child and the natural mother of the child currently reside on Santa Fe
Street in Pawnee Rock, Barton County, Kansa.s and have a mailing address of
P.O. Box 304, Larned, Kansas, 67550. The natural mother and child moved to
Western Kansas pursuant to an Order issued by the Han. Jan Leuenberger on or
about May 20, 1996; the natural father remained in Shawnee County, Kansas.
The natural mother. Claudine Dombrowski has been a resident of Barton County
for d Y a~~d has worked at the Larned State Hospital as a nurse for
~ \I Q l!.l,\~ . The natural mother moved to the Larned area to work for
the State Hospital as her position with the Topeka State Hospital was terminated.
Further, the naturaJ mother suffered great physical abuse at the hands of the
8/8/2019 5-21-1999 CINC Barton County to Keep Minor Child Safe From Abusive Father Dom Brow Ski
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A P R ~ 3 0 - 9 9 F R I 0 4 : 0 3 P M R I L I N G B U R K H E A D N I l C E RF A X N O . 7 8 5 8 4 3 0 1 6 1
natural father of the child and feared for her and her daughter's safety if she
remained in Topeka, Kansas .
.t The natural futileI', Halleck Richardson currently resides at 1727 Shawnee Heights
Road, Tecumseh, Kansas 66542. He is self employed.
S. Pursuantto K.SA 38-1303(1l)(3) this Court has jurtsdlction to make a child
custody determination as defined in the Uniform Child Custody Jurisdiction Act,
because the child is physically present in this state and it is necessary in an
emergency to protect the child because the child has been subjected to or
threatened with mistreatment or abuse or I Sotherwise a child in need of care.
6. Pursuant to K SA 38-1503 this Court has jurisdiction ~t:;he parti~ aliathe----..-_. _.
subject matter of this proceeding.
7. Pursuant to KSA 38-1504 venue is properly had in Barton County, Kansas.
8. Said child is in need of care because she bas been physically, mentally or
emotionally abused or neglected or sexually abused by her father. Halleck
Richardson. Further, Mr. Richardson has provided only two month's worth of
support for his four year old daughter since she has moved to Western Kansas.
9. Mr. Richardson has had no contact with the minor child since March 5, 1998. At
that time, he shortened a court ordered visit because he couldn't keep the minor
child from being hysterical. Having no contact with the minor child in almost one
(1) year is a "physical, mental or emotional neglect" of a child as well showing a
"lack of effort on the part of the parent to adjust to the parent's circumstances,
conduct or conditions to meet the needs of the child." (see, KSA 38-1583(b) (4)
and (8».
8/8/2019 5-21-1999 CINC Barton County to Keep Minor Child Safe From Abusive Father Dom Brow Ski
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A P R - 3 0 - 9 9 F R I 0 4 : 0 3 P M R I L I N G B U R K H E A D N I T C E RF A X N O . 7 8 5 8 4 3 0 \ 6 \ P , 1 01 1
physician is located in Great Bend, Kansas.
10. That the minor cIiiId has seen a psychi3triSt due to the abuse and neglect of her
natural father, and, this psychiauist is located in Grcat Bend, Kansas.
11. When Rikki was returned to Ms. Dombrowski after a five (5) day stay with Mr.
Richardson on or about March 5, 1998, the minor child showed signs of neglect
and possible abuse for which Ms. Dombrowski sought medical treatment. (see
K.S.A. 38.1583 (b)(2).) This doctor confirmed that there was neglect and
confirmed possible abuse due to the fact that the cliiId was unv.-ashed,
undernourished, was not wearing any underwear. Further, the doctor found some•
black hairs in the child's genital region thllt,.appeared to be adult pubic hairs. This-, '- " ...- . - . -
12. Because of the above described visit, the natural father refused to undergo alcohol
evaluation and voluntarily suspended visitation with his child.
13. That the day eare provider.; where the IIlinor child attends, documented the
adverse affect that visiting her father had on the minor child. The day care
providers noticed, for example, that the minor child would be overly agree;sive
upon returning from her father's, could not relate well with other children and
would be withdrawn and confused. It would take two weeks for the child to
return to nonnal after visiting her father. The day care providers live and work in
Lamed, Pawnee County, Kansas.
14. That the minor child screamed hysterically during phone conversations while with
hCt' father during the times 111111the mother could talk to her.
IS. That the minor child screams hysterically at the thought ofhaviog visitation with
her f'dthc:rand calls him her, "mean daddy.-
8/8/2019 5-21-1999 CINC Barton County to Keep Minor Child Safe From Abusive Father Dom Brow Ski
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A PR -30-99 FR I 04:04 PM R ILIN G B U R K H E A O 'N ITC E RF A X N O . 7 8 5 8 4 3 0 1 6 1 P . 1 1 / 1
16. Mr. Richardson has only paid child support for two months of the child life. even
though she has lived apart from him for over ~~ears. He has not provided
insurance coverage tor this child during any part of her life and has Dot paid for
any of her physical or emotional needs, He is clearly neglecting his common law
duty to aid in the monetary support of his child. (sec KSA. 38.1583 (b)(4).)
17. Mr Richardson has a history of physical violence against the mother, Claudine
Dombrowski as well as a history of substance abuse and trouble with the law due
to his anger and substance abuse. (see KSA 38-1583(b)(3»
WHEREFORE, THE PETITIONER, Claudine Dombrowski, Requests that the minor
18. That this child is in need of court protection,as the father is a physical,~--._.. _ - _ .- - _ .- - - -emotional threat to her.
sexual and
child, Rikki Dombrowski, be declared a Child in Need of Care.
VERIFICATION
STATE OF KANSAS )) ss:
COUNTY OF I3o"s::+o1/':.)
Claudine Dombrowski, oflawfu1 age, being first duly sworn on oath, states as foUows:
That she is the Petitioner in the above-entitled action; that she has read the foregoingP '" " " " • • • • • • • • • •oh. """""" """" •••• _ .l< ••••••••• """" ••~~ ave ••••correct ~
' .\:>..)~Claudine Dombrowski. PetitIOner
8/8/2019 5-21-1999 CINC Barton County to Keep Minor Child Safe From Abusive Father Dom Brow Ski
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~ P R - 30 -9 9 F R I 0 4:0 4 P M R I L I N G B U R K H E A D - N I T C E RF A X N O , 7 8 5 8 4 3 0 1 6 1 P.12/19
Subscribed and sworn to before me this f ! ! I .day of 5 , 1999_
~' 00 O Wr-l\&.J(oif Notary Public
RILING, BURKHEAD,& NITCHER, Chartered
808 Massachusetts Streetp, O. BoxBLawrence. Kansas 66044(785) 841-4700Attorneys Respondent
_.e-' -_.-..;..::: ::_
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