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IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION – LAW

“EXHIBIT R”

BENNETT J. VONDERHEIDE :
Plaintiff,

v.

CALVARY CHURCH :
Defendant,

v.

Wendy Flanders
Defendant

v.

Others Listed Herein As Item 1. COMPLAINT PARTIES

K. Exhibits

Exhibit R., The Name Game

Quinta Xavier Vonderheide

Chronological Outline of Name Changes

Quinta Xavier Vonderheide

A. 6/24/98 Born at home – name undecided.

B. 6/29/98 Parents agree to Quinta Xavier Vonderheide, Ms. Flanders handles all paperwork associated with birth and birth certificate.

C. 6/29/98 – 3/15/2002 Child uses given name “Quinta Xavier Vonderheide” only and everywhere.

D. 6/30/99 (approx.) Father finds out birth certificate was originally incorrectly issued as Quinta Xzavier Flanders. Mother agrees to change.

E. 3/13/02 Ms. Flanders attempts to disappear with the child into the Underground Railroad for abused women. Trying to assign the child a new name and identity and take the child forever away from his father and all paternal connection as well as her own family. Ms Flanders attempted this although under court order and the Guardian Ad Litem program with one of the other children she was taking with her.

F. 3/15/02 Mother files first PFA against father listing child’s name as Quinta Flanders.

G. 3/15/02 – present. Mother permanently uses name of Quinta Flanders to separate child from father and cause conflict (see Motion). Change of name is utilized to place the child as pawn for Ms. Flanders pattern and history as it repeats itself.

H. 6/21/02 Mother files second PFA against father listing child’s name as Quinta Flanders.

I. 9/5/2002 – present. Child is identified in all custody filings as Quinta Xzavier Vonderheide and Ms. Flanders states directly to custody conference officer that the Childs' name is Quinta Xzavier Vonderheide.

J. 2/13/03 Ms. Flanders officially changes the child’s name again on the birth certificate. This time from Quinta Xzavier Flanders to Quinta Flanders. Thus eliminating any reference or connection to the paternal grandfather (Paul H. Vonderheide who proudly attended Xavier University in Cincinnati, Ohio). Again using the child as a pawn to offend the father and his family with the prime result being to confuse the child and make him feel bad about and separate from his father and his fathers’ entire side of the family.

K. 7/24/03 Registered for kindergarten as Quinta Xzavier Flanders, under SS# space Ms. Flanders wrote (Uses Vonderheide).

L. 8/03 (only date shown) Listed for school as Quinta Flanders (Vonderheide).
Noteworthy on these documents are the references to parents being divorced although they were never married and the listing of mother as Mother/Substitute Teacher while father is listed as “Unemployed” with “Self” listed as the firm. That makes Mr. Vonderheide “self unemployed”.

M. 6/30/99 – 4/30/04 Mother finds reason after reason correction is not affected. Including having her attorney represent that document is prepared and across the street to correct the name to Quinta Zavier Vonderheide.

N. 5/23/04 Typical of past experience Mother attempts to pull a fast one and change name to Quinta Xavier Vonderheide Flanders. Thus we are back again.

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