Claudine Dombrowski

P.O. Box 15212

Kansas City, MO. 64106
Phone: (785) 845-3417
Fax: (775) 806-3730
June 4, 2004

RESPONSE OF RESPONDENT TO THE LETTERS TO THE COURT OF DR. ALBOTT

AND CASE MANAGER LLOYD SWARTZ, RESPECTIVELY SENT MAY 26, 2004 AND
MAY 7, 2004

His Honorable David E. Bruns:

Upon review of Dr. Albott’s letter to this Court of May 26, 2004, and subsequent review of Case
Manager Lloyd Swartz’s earlier response to Respondent’s pending motion before this Court, for
removal of restricted visitation and removal of Lloyd Swartz for cause as Case Manager, I wish to
make the following observations and statements for the record that I believe are material to the
decision-making process by this Court in the matter of my visitation in the instant case, as well as
to provide substance and recorded history to any future procedures in this or other Courts of
jurisdiction:
1) Dr. Albott’s letter to the Court directly contradicts what the Case Manager’s May 4, 2004 letter
to me and copied to the Court states relative to my compliance with Dr. Albott’s
recommendations for Case Management in the instant matter before the Court. According to
Case Manager Lloyd Swartz in his May 4, 2004 letter:

“I also did not cause your supervised visitation to be cancelled. After it was cancelled I
was advised by Dr. Albott that you failed to follow through on the conditions they set on the
visit.”

Dr. Albott states in his letter to the Court that the reason for canceling the scheduled supervised
visitation to be overseen by Dr. Rodenheffer was due to legal issues surrounding the issuance of a
Full Order for Protection issued on behalf of Claudine Dombrowski, Petitioner, against Halleck
Richardson, Respondent, by the Circuit Court for Platte County, Missouri. This Full Order of
Protection issued by the Platte County, Missouri, Circuit Court, in no way names or involves Dr.
Albott, or anyone else other than Halleck Richardson. Moreover, there was no
attempt to contact me by either Dr. Albott or Lloyd Swartz to ask
for any information relative to said Full Order of Protection, and the circumstances surrounding the
need for such issuance as seen fit by the Circuit Court for Platte County, Missouri. In fact, Dr.
Albott in his letter comments at page 2, paragraph 2, that,

“On 3/21/04 Mr. Richardson called my office indicating that a protective order had been filed
in Platt (sic) County and that he wanted to discontinue visits...” (my emphasis).

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No one made the first attempt to contact me to notify me of Petitioner’s stated desire to end co-
parenting counseling, or to arrange for a Mother/Daughter visitation that both preserved the safety
of the Respondent in this ongoing saga before this Kansas court, and also protected the legal rights
and concerns of the Petitioner, Halleck Richardson. Certainly, a perfectly legal and amenable
visitation could have been arranged by the parties under Case Management if anyone had simply
contacted me to arrange for such a visit. I was never informed of the detailed rationale for
canceling the supervised visitation by either the Case Manager or Dr.’s Albott and Rodenheffer, or
anyone else. Now it is apparent that Dr. Albott and the Case Manager, Lloyd Swartz, disagree as to
the real cause of my scheduled supervised visitation having been cancelled. Moreover, on April 1,
2004, only 12 days before my rescheduled visit with my daughter with Dr. Rodenheffer, Lloyd
Swartz is witnessed to have threatened me over the telephone with either dropping the Full Order of
Protection filed in the Circuit Court for Platte County, Missouri, within 5 days or face a “contempt
of court” citation filed by Lloyd Swartz in the Kansas Court. He is also witnessed to rudely state,
“Why don’t I believe you?” when he asked me during that phone call for my residence address.
This behavior on the part of Lloyd Swartz along with the statement below of Dr. Albott leads me
to conclude that the Case Manager did in fact know of the details prior to the cancellation of my
scheduled visit with my daughter. Dr. Albott states in his letter at page 2, paragraph 2, that after he
had spoken to Hal Richardson on “3/21/04” that:

“Following this call I contacted Lloyd Swartz and yourself as to how to proceed. I also spoke
with Mr. Hoffman (attorney for Mr. Richardson).”
Neither Dr. Albott nor anyone else involved in this matter spoke with me or my attorney of record
at the time, Leonard Robinson on or about the time Dr. Albott spoke with the Petitioner, his
Attorney, Don Hoffman, and the Case Manager, Lloyd Swartz. In fact, my first contact with
anyone was Dr. Albott’s secretary on Mar 23, 2004, to reschedule the visitation with my daughter
under the supervision of Dr. Rodenheffer, as I had mistakenly forgotten the exact time for the first
scheduled visit until 30 minutes prior to said scheduled visit, and was physically at that time in
Kansas City, Missouri. I called Dr. Albott’s office immediately and the visit was rescheduled for
April 13, 2004 by his secretary.

I want to note for the record that Dr. Albott’s contact with Counsel for Petitioner includes by his
own admission details of “how to proceed” in this matter. I find this contact inappropriate in light
of there being no similar contact with me or my attorney of record at the time. I also note that Case
Manager Lloyd Swartz’s evidenced gross bias against me, personally, is manifest by his demeanor
and behavior during the April 1, 2004, telephone contact. I can only assume any contact between
him and Dr. Albott as to “how to proceed” is also biased against me and my interests in this matter.

2) Dr. Albott’s letter states clearly in his second paragraph on page 1 that he met with the parties
15 times from August 2002, to April 2003, at which point the Petitioner,

“...Mr. Richardson abruptly left the session and terminated the (counseling) process.”

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In the last of those 15 “historical” sessions it was the Petitioner, not the Respondent, who
demonstrated unwillingness to comply with continued counseling and simply walked out, thus
terminating the process. I in no way during those sessions did anything to not comply with Case
Management and counseling, and Dr. Albott’s statement fully supports that position. Moreover, the
statement of Dr. Albott in his most recent letter to this Court and His Honor specifically points out
that Hal Richardson stated his intent to end the most recent co-parenting counseling under Dr.
Albott. For the record, it is the Petitioner, Halleck Richardson, who has on his own ended both
Court ordered co-parenting sessions under Dr. Albott. That the Case Manager states that my
visitation with my daughter is due to my own being uncooperative with Dr. Albott simply defies
logic in view of this established fact that the Petitioner ended both rounds of counseling sessions
by his own actions, according to Dr. Albott.
3) In that same second paragraph of Dr. Albott’s letter, he states that the “immediate complaints”
at hand in this most recently ordered series of counseling sessions regard my ongoing
complaints of the Petitioner unduly restricting and denying my parenting time with Rikki, while
“....Mr. Richardson’s complaints were about Ms. Dombrowski frequently appearing in
locations where the daughter was scheduled for some activity and acting inappropriately.”
Dr. Albott does not define what “inappropriately” means nor does he specifically allude to any
particular event where such alleged inappropriate behavior occurred – not one specific event .

It is most noteworthy that none of the Petitioner’s immediate “complaints” before Dr. Albott
even mention the alleged “Biker Group” B.A.C.A (Bikers Against Child Abuse) nor does any
alleged “threat letter” to the Petitioner come up in any of the three most current round of
counseling sessions held by Dr. Albott with the parties, nor does the Petitioner express any
indication of concern for his harm as alleged in the original complaint made by Petitioner to the
Case Manager Lloyd Swartz as witnessed by “Recommendation of Domestic Case Manager,
February 2004.” Indeed, in none of these three counseling sessions does the Petitioner
according to Dr. Albott’s letter make mention of the very basis and allegations used by the
Petitioner to have the Case Manager file his February 2004 recommendation to have the parties
return to counseling and to restrict my visitation with my daughter. Moreover, those three
counseling sessions were held on or about the end of February 2004 into March 2004. No such
case of alleged inappropriate actions by the Respondent has been proffered by the Petitioner for
any time prior to the Petitioner’s ending of co-parental counseling.
Petitioner has since sought to enter for this Court’s consideration alleged events that Counsel
for Petitioner seeks to subpoena; such events as alleged by Petitioner to have occurred well
after the ending of counseling with Dr. Albott in March and even further removed from the
original complaint filed by the Petitioner with the Case Manager in February 2004, and upon
whose unfounded allegations Case Manager Lloyd Swartz immediately made his
recommendation to the court for more costly co-parenting counseling and at the same time
recommend supervised visitation by the Respondent. . It is also worthy of note that none of
these alleged inappropriate acts on the part of the Respondent appears in the original Case
Manager recommendation as a cause for his recommendation to restrict visitation. Such
restriction was based largely on the alleged stated comments of the 9 year old child to Dr.
Rodenheffer, accompanied by her father the Petitioner, regarding the Respondent allegedly
discussing doing bodily harm to the Petitioner with B.A.C.A. .

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 Not one scintilla of evidence has been proffered by Petitioner to support his instant motion
before this Court, notwithstanding there is credible evidence - refused by the Case Manager
when proffered – that such a conversation by the Respondant never took place during the time
alleged by Petitioner, and upon whose allegation the Case Manager recommended restricted
visitation under the Safety Program, normally reserved for adjudicated abusive parents, which
Dr. Albott agrees no such evidence exists in his professional opinion that the Mother is abusive
at all, much less meeting the criteria for forced supervised visitation through the Safety
Program. With all due respect to this Court and His Honor, it is my belief that the court
appointed Case Manager, Lloyd Swartz, has demonstrated his willingness to take draconian
actions to restrict my unsupervised visitation with my daughter based solely on the statements
of the Petitioner, Halleck Richardson, and the dubious statements of a 9 year old child in the
presence of her convicted criminal and demonstrably recalcitrant father, who has twice now
ended both Court ordered rounds of co-parental counseling – once by physically walking out of
counseling and now by telephone to Dr. Albott to declare his intention to end co-parental
counseling, and stop the prearranged visit between mother and daughter under the supervision
of Dr. Rodenheffer.
4) There is a material difference between being “unwilling to accept Safe Visit” and being
“uncooperative” as I was stated to be by Case Manager Lloyd Swartz. Since the supervised
visitation overseen by Dr. Rodenheffer was in fact scheduled, it cannot be the case I was any
more “uncooperative” than the Petitioner, who stubbornly demanded supervised visitation
under the “Safe Visit” program. I was “unwilling” to subject myself and my daughter to what in
effect was an unwarranted approach to visitation with future implications for yet more use of
the Courts by Halleck Richardson to assault me – physically, psychologically and financially.
Dr. Albott himself states that in his professional opinion there is nothing to suggest the
Respondent is a physical danger to her daughter that merits the “Safe Visit” program as the only
viable supervised visitation modality.
.
5) Despite the Case Manager’s stated allegation that the reason my scheduled supervised visit with
my daughter was cancelled was because I did not follow Dr. Albott’s counseling guidelines,
what we now hear from Dr. Albott in his letter to the Court is that Dr. Albott’s office is not “set
up” to deal with parental exchange or may otherwise infringe upon the Full Order of Protection
issued by the Circuit Court for Platte County, Missouri, and that is why my supervised
visitation was cancelled. May it please the Court to consider that these two dichotomous
versions by Lloyd Swartz and Dr. Albott of why my supervised visitation was cancelled are
completely different. Moreover, I was never consulted or asked for input as to how to resolve
this dilemma, even though I am certainly one of the Parties best in a position to provide such
input. Instead, Dr. Albott reports discussing it with the Case Manager, as well as Counsel for
the Petitioner. I find this process patently unfair and especially so when the result is continued
denial of visitation with my daughter for well over 125 days now, with no material evidence to
support any such need for this denial. Nothing in the Full Protective Order issued in Platte
County, Missouri makes this exchange for purposes of visitation overwhelmingly complex. We
could easily meet at any police station or other “suited” place to exchange instant custody of the
child for purposes of my visitation. I believe it disingenuous to suggest that any legitimate
professional actions on the part of Dr. Albott could be construed to place him or Halleck
Richardson in violation of the Full Order for Protection.

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6) For His Honor’s information, my unwillingness to accept “Safe Visit” is hardly because I do
not want to see my daughter. My therapist and any number of witnesses can attest to the pain
and anguish that I have to endure in not seeing my daughter for well over 125 days. But, as His
Honor can readily see, what was once a simple issue of an alleged “Biker Group” (which soon
was revealed to be a legitimate and fully legally organized benevolent association) now
becomes a fishing expedition for anything that Counsel for Petitioner can try to make stick,
with alleged events post hoc to the original motion before this Court by Petitioner Halleck
Richardson. It is my position that “Safe Visit” or even any supervised visitation on my part is
unwarranted and unnecessary, and only serves the purpose of the Petitioner to directly control
my life and my daughter’s contact with me. It also serves the Petitioner’s interest in the future
Court motions that will emanate from the Petitioner as surely as the sun will rise tomorrow.

7) On March 21, 2004, Petitioner contacted Dr. Albott to purposefully end the Court Ordered co-
parental counseling, as Dr. Albott reports in his letter to His Honor of May 26, 2004. For the
record, as of that date the Petitioner had only been served notice of hearing for said protective
order, to be held April 6, 2004 in Platte County, Missouri Circuit Court. While a temporary
order of Full Protection was duly ordered by the Honorable Judge Czemanske on 3/24/04
pending full hearing, Halleck Richardson failed to appear either in person or through Counsel at
the April 6, 2004 hearing. Hence, the Full Order for Protection was ordered by the Platte
County, Missouri Circuit Court with the Respondent in that matter, Halleck Richardson, being
in default by failure to appear. Richardson had every opportunity to appear or be represented
by Counsel at that hearing if he wished to deny or respond to the evidence proffered by
Petitioner Claudine Dombrowski and upon which the Platte County, Missouri, Circuit Court,
found cause and duly ordered Full Protection for Ms.Dombrowski from Halleck Richardson.

8) Case Manager Lloyd Swartz did willfully on April 1, 2004, threaten Ms. Dombrowski with
“contempt of court” if she failed to withdraw the motion before the Platte County, Missouri
Circuit court “..within 5 days.” That the “5 days” alluded to by Lloyd Swartz at that time
coincides with the scheduled hearing in the Circuit Court for Platte County, Missouri, is
circumstantially significant to an argument for nexus between the scheduled hearing , the
willful failure to appear or respond by Halleck Richardson, and the 5 day time frame given to
Ms. Dombrowski by telephone on April 1, 2004, by Lloyd Swartz to withdraw said Motion or
face a contempt of court recommendation by Swartz to His Honor, Judge Bruns of the Kansas
Court of jurisdiction in this matter. Given the established but unknown extent of informal and
unrecorded ex parte communication between Richardson, Dr. Albott, Case Manager Lloyd
Swartz, and Counsel for Petitioner, Don Hoffman, it defies credulity that there exists no such
nexus. I submit such nexus exists and supports my Motion before this Court that Case Manager
Lloyd Swartz has demonstrated undue and gross bias against Respondent, and that his
recommendations to this Court are clearly so biased. Moreover, I submit the recommendations
of the Case Manager relative to “recommending” supervised visitation is simply punitive in
nature against Ms. Dombrowski on the part of the Case Manager and have no foundation.

9) I note for the record Dr. Albott’s comments found in his 5/26/04 letter to the Court at page 2
regarding his determination that evidence proffered by Ms. Dombrowski to the Missouri Court

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 relative to an incident in an unspecified parking lot in which Halleck Richardson is alleged to
have threatened Ms. Dombrowski with death on March 8, 2004, was his office parking lot. He
further states his “recollection” of events that day is that Petitioner Halleck Richardson left the
parking lot before Ms. Dombrowski did, and that he did not witness any such threat or recall any
interaction between Richardson and Dombrowski. These are curious comments, the legal
equivalent of someone stating he was not in the forest but doesn’t recall hearing the tree fall.
That Dr. Albott fails to recollect an event he did not witness is beyond understanding to make
comment upon, and adds no material value to substantiating that the event took place or not.
This comment by Dr. Albott is more disconcerting given his admitted ex parte communication
with the Petitioner and Petitioner’s Counsel, Don Hoffman, to the exclusion of any similar
contact with the Respondent or her Counsel of record at the time.

I respectfully ask His Honor to carefully weigh the recommendation of Dr. Albott that he has “no
alternatives” to the Safe Visit program in light of the evidence of record, as well as the unknown
and unrecorded ex parte communication as described herein between Richardson, Albott, Swartz
and Hoffman. Dr. Albott at the same time states there is no formal allegation – much less evidence
– of Respondent having “…physically abused her daughter.” Moreover, the very Order for Full
Protection issued by the Platte County, Missouri, Circuit Court, was never challenged by Petitioner
Halleck Richardson when he had every opportunity to do so. Now Petitioner and his Counsel see
fit to use this order of the Missouri Court as a basis to further deny my access to my daughter,
while engaging in a fishing expedition for evidence – real or contrived – to further extend this
matter before the Court.

I formally ask His Honor to consider the default of Halleck Richardson to appear or otherwise
respond to the Platte County, Missouri Circuit Court in the matter of an order for Full Protection to
constitute by default acknowledgement that the evidence considered by the Missouri Court to be
stipulated to by Halleck Richardson for purposes of presenting evidence to this Court in the instant
matters before this Court.

I also formally ask His Honor to consider these issues in making a finding regarding unsupervised
visitation of my daughter. If His Honor so desires, I am willing to engage in an informal conference
in chambers to flesh out the issues in this matter before all Parties.

Respectfully,

Claudine Dombrowski, Respondent

Cc: Dr. Albott

Dr. Rodenheffer
Lloyd Swartz
Amanda Smith CSO
Don Hoffman
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