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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT F”

BENNETT J. VONDERHEIDE
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT F”

BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

Exhibit F. Memo to DEFENDANT George May and DEFENDANT Todd Nathan Concerning PLAINTIFF’S Minor Son QXV from DEFENDANT Kathy Yoder

May 23, 2004

TO: George May, Todd Nathan
FROM Kathy Yoder
RE: Quinta Vonderheide

As you both know the situation with Wendy and Ben has escalated in that Ben is seeking full custody of Quin. Quin stayed with Ben several time in the last two weeks and here are the results of those visits.

1. Quin missed baseball practice and games
2. Quin missed Mystery night at school 2where their teacher for next year and had a treasure hunt
3. Quin missed Sunday school.

Quin is very discouraged and asked to speak to me. He is five years old and very articulate for a child. His concerns are as follows: (I am trying to give you his exact verbiage as much as I wrote down.)

1. Daddy thinks mommy has a new boyfriend. First it was (I forgot the name) [“Mathew” hand written above] and now he thinks its Skip. It isn’t true but Daddy keeps saying Mommy is sneaking off with him.
2. Daddy says a lot of bad words, all the time. (I asked Quin – do you ask daddy to stop saying bad words?) Yes, and he says – Move on. It hurts my feelings when he says bad stuff about mommy. It isn’t true. It is very annoying.
3. He didn’t get me back in time for the mystery night at school
4. daddy doesn’t take me to baseball. He is supposed to take me to baseball but he doesn’t.
5. He doesn’t take me to my Sunday school class. I wish he would.
6. He talked about Ben saying “we’ll fix it” about Mommy but I didn’t get the whole context of that and we moved on to something else.

Quin clearly said he loves his dad and wants to see his cousins etc. But he iis afraid to go with Ben because Ben said he’s going to ‘keep’ Quin and he is afraid he will miss the ‘party at school’ and other activities. He’s afraid Ben is going to keep him ‘a long time.’

Quin asked me if I would have someone talk with his dad about his ‘bad words’ and keeping him too long and I said I would check with you guys and let you handle it. He was visibly relieved. I don’t know if talking to Ben will actually accomplish anything. Quin seems to feel very frustrated with his dad. He’s old enough now to repeat this stuff and to be able to articulate the problems to others. Let me know how you feel we should proceed.

 

 

K. Exhibits

A. Current Custody Order Of Judge Wayne G. Hummer, Jr. In The Case Of Quinta Xavier Vonderheide 08.06.02

B. PAS: How to Detect It and What to Do About It 11.99

C. A Guide To The Parental Alienation Syndrome 03.99

D. Kathy Yoder E-Mail to Principal Pavlovec 11.17.04

E. Pennsylvania State Code CHAPTER 49. LICENSURE OF PROFESSIONAL COUNSELORS 04.02.02

F. Memo from DEFENDANT KY to DEFENDANT GM and DEFENDANT TN Concerning PLAINTIFF’S Minor Son QXV 05.23.04

G. Letter to DEFENDANT George Duff from PLAINTIFF Attorney Longo 11.22.04

H. ACA Code of Ethics and Standards of Practice 1995

I. Letter To PLAINTIFF Attorney Longo From DEFENDANT CC Chairman of Elders DEFENDANT George Duff 12.07.04

J. Letter to PLAINTIFF Attorney Longo From DEFENDANT Jeffrey A. Feirick Denying and Including Records 01.03.05

K. Philhaven Evaluation by DEFENDANT OO 7.23.04

L. Philhaven Treatment documents from DEFENDANT AK 10.04 – 01.05

M. Letter To Parent or Guardian From Philhaven Requesting Release Signature; Sent to Plaintiff After Having Performed Treatment on His Son 01.14.05

N. The Principles of Medical Ethics With Annotations Especially Applicable to Psychiatry 2001 Edition 2001

O. DEFENDANT WF Abuse of Process Timeline 03.02 – 12.04

P. DEFENDANT WF and DEFENDANT KY DEFENDANT CC Interaction Timeline 02.02 – 11.04

Q. Quinta Quotes 05.04 – 02.05

R. The Name Game 06.98 – 05.04

S. Letter to DEFENDANT BM from PLAINTIFF Attorney Longo 12.21.04

T. Name Change Order Of Judge Perezous 10.14.04

U Mountville Family Practice Treatment Notes for the Minor Child QXV 07.09.98 – 02.01.05

V. Adderal Article- CANADA PULLS HYPERACTIVITY DRUG OFF MARKET 02.11.05


W. Remeron Article: Suicide Warning Ordered On Drugs 10.16.04


X. Letter to DEFENDANT WF From Dr. Parke Mountville Family Practice 02.15.05


Y. Letter to PLAINTIFF From Dr. Parke Mountville Family Practice 02.15.05


Z. Letter to Principal Colleen Pavlovec From DEFENDANT WF Attorney Wolman 11.01.04


AA. CV Exceptional Student Evaluation 04.11.05

BB. Letter To PLAINTIFF From Francis D. Sparrow, M.D. Philhaven Medical Director Clearing Quinta of Medical Aspersions 02.10.05

Lawsuit Pages: 1, 2, 3, 4, 5

Lawsuit Web Page 1.

A. COMPLAINT PARTIES

Lawsuit Web Page 2.

B. FACTS

Lawsuit Web Page 3.

C. COUNT I DEFAMATION
D. COUNT II BREECH OF CONFIDENTIALITY
E. COUNT III ABUSE OF PROCESS

Lawsuit Web Page 4.

F. COUNT IV ALIENATION OF AFFECTION
G. COUNT V. NEGLIGENCE

Lawsuit Web Page 5.

H. COUNT VI. VIOLATION OF COURT ORDERS RELATING TO QUINTA XAVIER VONDERHEIDE
I. OBSTRUCTION OF JUSTICE
J. PRAYER FOR RELIEF
K. EXHIBITS