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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT O”

BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

Exhibit O., Abuse Of Process Detail/Timeline

DEFENDANT Wendy Flanders' Accusations Against Mr. Vonderheide

ABUSE OF PROCESS DETAIL/TIMELINE

3/14/02 CI# 02-02219 1st Protection From Abuse (PFA) & Eviction served

• 8/2/02 Stipulation Agreement Order filed (couples counseling) – ran course 10/30/02

3/16/02 1st Indirect Criminal Contempt (ICC) attempt: I say, “I Love You” to Wendy in front of officer.

• I go to the station and the District Justice advises that I need to 'get out of town' and not speak to Wendy.

3/21/02 2nd ICC attempted. From basement Bob and I send up list on elevator as per Wendy’s request (she is on second and third floor).

• Police come and take me away. Officers state I am lucky who is on “ADA” and I am released. The person who was scheduled on violates everybody no matter what. I am told they got grief for not arresting me for the “I Love You” statement the week before.

3/28/02 Labor & Industry complaint “living in unsafe conditions”. Could not do site inspection through reported area due to PFA in place (great trick).

• Recently finalized and satisfied at a cost of tens of thousands to update two old buildings.

4/06/02 3rd ICC attempted for threatening to change locks and harassing her about a check she had forged.

• Chief Boozer calls DA – no arrest – I get chewed out and threatened by Chief Boozer – going to jail, etc.

5/20/02 (approx.) 4TH ICC attempted for introducing myself to two men emptying my building of property “mine”.

• Officer speaks to DA – no arrest

5/23/02 (approx.) On phone with police to file fifth violation on cable TV being knocked out for a couple minutes.

• I satisfy her as she is calling them.

5/27/02 (approx.) Threatens to file ICC if I call again to see Q over Memorial Day holiday (day before court).

6/10/02 CI-02-02219 PFA #2 “Stalking” This PFA executed using the therapy sessions ordered by the court as the primary tool, i.e. I follow the direction of therapist and Wendy uses the actions to charge. Specifically calls to speak to and/or see Q.

• Plea bargained to 60 day non admission of guilt due to inability to get hearing after numerous continuances
7/09/02 NT-0000657-02

• Became

8/23/02 Docket #0228S2002 Criminal Harassment

• 10/30/02 NOT GUILTY Judge Cullen

9/08/03 Docket #CR-0000303-03 Criminal Harassment

• became;

12/26/03 Docket #5692CR2003 Criminal Harassment

• 5/13/04 NOL PROSE Cost On County

9/22/04 CI# 04-08725 PFA#3

• Oct 25th hearing Rescinded towards Quinta for lack of preponderance of proof amended for Wendy to stay in car during transfers. Record at Prothonotary's states in place until April 20, 2006. I remembered being told this was a six-month only PFA – did they change it when we weren't looking?

10/16/04 Docket #NT- 0000651-04 Criminal Harassment (private criminal complaint) Identical claims and instance of PFA that was rescinded/amended this same day in court.

• Pending

10/25/04 Report #04-1555-C Code: 8404 Indirect Criminal Contempt

• Taken to police station and read my rights. I then showed the current PFA ruling by Judge Workman and they released me. Police and ADA Dye see if charge of false statement is warranted because victim did not tell Officer Fedor about most recent order.

11/30/04 Docket #No:MD180-04 Indirect Criminal Contempt

• 12/9/04 Nol Prose. ADA and Lancaster Police want to prosecute Wendy for false swearing. Video tapes being retrieved. Arrested in front of son, son taken away to Wendy by police. Night in jail released on $7,000 ROR after arraignment.

 

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