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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT J”

BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

J. Letter to PLAINTIFF Attorney Longo From DEFENDANT Jeff Feirick

Jeffrey A. Feirick
4109 Forest Rd.
Mount Joy, PA 17552
Home: (717) 684-7384

January 5, 2005

VIA FACSIMILE (717) 397 - 5267
Lucille Longo
Hahneman, Longo & Longo
15 North Lime Street
Lancaster, PA 17602

RE: Quinta Vonderheide Counseling Records at Calvary Church

Dear Ms. Longo,

I represent Calvary Church in the Ben Vonderheide matter. On December 30, 2004, I received a call from Mr. Ron Hoover, requesting Quinta’s Calvary Church counseling records for Mr. Vonderheide. After that call from Mr. Hoover, I contacted you and discussed the fact that the February 6, 2003 Custody Order is the effective Order. In response to your client’s request for Quinta’s counseling records, I submit the following information to you and your client:

There are no formal written records on Quinta Vonderheide at Calvary Church.
The one document that discusses Quinta Vonderheide and counseling found in the Calvary Church files in the May 23, 2004, memo from Kathy Yoder to George May and Todd Nathan (see enclosure).
In 2001, Quinta participated with other children in a “Kids Hope” Divorce care Group led by Kathy Yoder. The children played games, talked about their situations, gave prayer requests and prayed for their families. No counseling records were kept.
In the Fall of 2004, Kathy Yoder led a divorce care group with children including Quinta. Kathy had the children make a notebook. On the last Divorce Care meeting, the children took the notebooks home.
Kathy Yoder has met individually with Quinta several times as a pastoral care counselor. No formal counseling records were kept on these sessions.

The above-mentioned information is submitted to comply with the request from your client.

Sincerely,

Jeffrey A. Feirick
Attorney

Cc: Bad Mullen
George Duff

Enclosure: May 23, 2004 Memo from Kathy Yoder to George May and Todd Nathan

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