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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA


CIVIL ACTION – LAW

“EXHIBIT I ”


BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

I. DEFENDANT GD's Letter to PLAINTIFF Attorney Lucille Longo


December 7, 2004

Ms. Lucile Longo
15 North Lime Street
Lancaster, PA 17602


Dear Ms. Longo,

I am writing to confirm that I have received your letter of November 24, 2004, in which you, on behalf of your client, Ben Vonderheide, is considering legal action against

Calvary Church Calvary Church is committed to promoting the restoration of broken relationships and the well being of children. We want to respond to your request. However, since your letter makes specific accusations requiring assessment and since I will need to consult with the several church leaders you copied in your letter, allow us to respond to your letter by January 15, 2005.

In the mean time, be assured that Calvary Church will give sincere and prayerful attention to this matter.

Sincerely,


George Duff
Board of Elders, Chairman

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
B. FACTS
C. COUNT I DEFAMATION
D. COUNT II BREECH OF CONFIDENTIALITY
E. COUNT III ABUSE OF PROCESS
F. COUNT IV ALIENATION OF AFFECTION
G. COUNT V. NEGLIGENCE
H. COUNT VI. VIOLATION OF COURT ORDERS RELATING TO QUINTA XAVIER VONDERHEIDE
I. OBSTRUCTION OF JUSTICE
J. PRAYER FOR RELIEF
K. EXHIBITS

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