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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT G”

BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

G. PLAINTIFF Attorney Longo’s Letter To DEFENDANT George Duff

November 22, 2004

George Duff
Chairman of Elders Calvary Church
1051 Landis Valley Road
Lancaster, PA 1760

Dear Mr. Duff:

As I am sure you are aware, I represent Mr. Ben Vonderheide in his current custody dispute with Wendy Flanders. The purpose of this correspondence is to advise you that my client is considering legal acting against Calvary church. It is my understanding that Kathy Yoder is employed as a counselor at your church. In her capacity as a counselor at your church, she has counseled Wendy Flanders as well as Quinta Vonderheide. I recently received information from the principal of Leola Elementary School that indicates to me that Me. Yoder is engaged .in a course of conduct that is totally inappropriate as an employee of Calvary Church.

The documents I have reviewed clearly indicate that Ms. Yoder has written derogatory and libelous comments regarding my client to the principal. She clearly identified herself as a counselor although she did not identify herself as an employee of Calvary Church. She went on to slander my client, both to the principal of Leola Elementary School as well as other employees and teachers at the elementary school that my client's son attends. Since her child also attends that school, all of those parties are aware that Ms. Yoder works for Calvary Church. I believe the church is clearly liable for the actions of its employees. In addition to your employee's slanderous conduct, she is also attempting to interfere with the custody of a child. She has interjected herself in a custody dispute between a mother and a father that is clearly acrimonious. She has attempted to sway those around and involved in the child's life against the child's father. Interfering in the custody of a child is a criminal offense in Pennsylvania. In my opinion, a civil action can be filed against both Ms. Yoder and Calvary Church.

1 . Ms. Yoder, her husband and others from Calvary Church physically moved the child away from Conestoga, the only home he ever knew. They interfered with my client's shared physical custody rights.

2. Ms. Yoder's counseling of the child has been harmful to the child because of her bias.

3. My client points out that for years he has attempted to notify Ms. Yoder's superiors and many others at Calvary Church, yet his attempts have been rebuffed and completely refused.
Based on his experience my client feels it is only fair that Calvary Church would do the following:

1. Be prepared to assist with NON-Calvary counseling for as long as it will take to remedy the psychological and emotional damage done by Ms. Yoder. .

2. Immediately stop Ms. Yoder, in her capacity with the Church, from having any contact whatsoever with the child.

3. Immediately turn over all records of therapy thus far withheld from my client, including any and all correspondence, notes, internal memos or any other material relating in any way to his son.

I believe Ms. Yoder's conduct to be particularly outrageous in that a professional counselor should certainly be aware that there are two sides to every story in a custody dispute.

By choosing to align herself with Ms. Flanders and accept everything Ms. Flanders has told her to be truthful is unprofessional and irresponsible. She is communicating to other people circumstances about which she has no first hand knowledge and that are unsubstantiated reports of a woman whose credibility is questionable.

I expect a written response to this correspondence indicating the Church's position in this regard. My client is justifiably concerned about the damage and impact your Church and it's employees have had and continue to have on his son. My client will thoughtfully consider your suggestions as to how this matter can be resolved in order to repair the psychological harm that has been done to his child.

If you choose to ignore this letter my client has authorized me to pursue legal action.

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