~ AP~~30-99FRI 04:02 PH RILING BURKHEAD NITGER FAX NO.

785 843 0161 P,08/19

COpy OF THE ORIGINAL
.. '~

FILED IN CLERK OF
DISTRICT COURT OFFICE
fQYtf"l _AS
~~~~ON
IN THE DISTRICT COURT OF BARTON COUNTY, KANSAS

In tbe Interest of )
)
RlKKI DOMBROWSKI )
ajuvenile 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 Ya ~~d has worked at the Larned State Hospital as a nurse for

~ \I Ql!.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
APR~30-99 FRI 04:03 PM RILING BURKHEAD NIlCER FAX NO. 785 843 0161 P.09/19

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 IS otherwise 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».
APR-30-99 FRI 04:03 PM RILING BURKHEAD NITCER FAX NO. 785 843 0\6\ P, 10119

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

physician is located in Great Bend, Kansas.

-, - .-.-'-" ...

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.-

APR-30-99 FRI 04:04 PM RILING BURKHEAO'NITCER FAX NO. 785 843 0161 P.11/19

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»

18. That this child is in need of court protection,as the father is a physical, sexual and

emotional threat to her.

~--._ _.--_.----
.. _-

-.J
I
WHEREFORE, THE PETITIONER, Claudine Dombrowski, Requests that the minor

child, Rikki Dombrowski, be declared a Child in Need of Care.

VERIFICATION

STATE OF KANSAS )
) ss:
COUNTY OF I3o"s::+o 1/':.)

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 foregoing
P'"""" •••••••••• oh. """""" """" •••• _ .l< ••••••••• """" ••~~ ave ••••
correct ~
' .\:>..)~
Claudine Dombrowski. PetitIOner
•. ~PR-30-99 FRI 04:04 PM RILING BURKHEAD-NITCER FAX NO, 785 843 0161 P.12/19

Subscribed and sworn to before me this f!!I. day of 5 ,1999_

~' 00 OW r-l\&.J(oif
Notary Public

RILING, BURKHEAD,
& NITCHER, Chartered
808 Massachusetts Street
p, O. BoxB
Lawrence. Kansas 66044
(785) 841-4700
Attorneys Respondent

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