I Timothy 5:20 [Elders] that sin rebuke before all!
I Timothy 5:20 [Elders] that sin rebuke before all!
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The following are news stories from 5thEstate.com about the case. Go to DaddyJustice.com to see more info on the father's struggle to simply see his son while having a powerful church, lawyers and the system fight to destroy him! Unrepented Leadership Trys to Cover-up!
See the photos Judge Hummer doesn't want you to see! He ignores everything and "father's" from the bench
Not A Pretty Pictures
The Timeline of a Railroad Job:
No Avoiding Conflict
Judge Hummer Wrote the Book!
Facing Jail Time
Sex Offender Gets Child
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What about the lawsuit? Many have asked for the documentation. Much of it is included in lawsuit as available below:
1. The PLAINTIFF Bennett J. Vonderheide (hereinafter referred to as "PLAINTIFF Bennett J. Vonderheide or PLAINTIFF BJV") is an adult individual residing at 3113 Main Street, Conestoga PA 17516. 2. The DEFENDANT Ms. Wendy Flanders (hereinafter referred to as "Wendy Flanders, DEFENDANT Wendy Flanders or DEFENDANT WF") is an adult individual residing at 68 W. Main St. Leola PA 17540 and is a Calvary Church Member.3. The DEFENDANT Ms. Emily Flanders is an adult individual residing at 68 W. Main St Leola PA 17540 and is a half sister to the minor child Quinta Xavier Vonderheide (AKA various names) and daughter of DEFENDANT WF. 4. The DEFENDANT Calvary Church is a registered non profit organization operating as a Church (hereinafter referred to as DEFENDANT CC”) and having offices at 1051 Landis Valley Rd, Lancaster, PA 17601. 5. The DEFENDANT Calvary Church Senior Pastor, Johnny V. Miller is an adult individual having offices at Calvary Church 1051 Landis Valley Rd, Lancaster, PA 17601. 6. The DEFENDANT Former Calvary Church Counselor Mrs. Ted Yoder (hereinafter referred to as "DEFENDANT Kathy Yoder, DEFENDANT KY”) is an adult individual who resides at 10 Glenbrook Rd. Leola PA. 17540.7. The DEFENDANT Calvary Church Member Ted Yoder (hereinafter referred to as "DEFENDANT Ted Yoder or DEFENDANT TY”) is an adult individual who resides at 10 Glenbrook Rd. Leola PA. 17540 8. The DEFENDANT Calvary Church Pastor of Counseling and Family Ministries George L. May (hereinafter referred to as "DEFENDANT George May or DEFENDANT GM”) is an adult individual with mailbox service at Calvary Church (address above).9. The DEFENDANT Calvary Church Pastor of Assimilation and Care, Mr. Todd Nathan (hereinafter referred to as "DEFENDANT Todd Nathan or DEFENDANT TN”) is an adult individual with mailbox service at Calvary Church (address above). 10. The DEFENDANT Calvary Church Member Mr. Elmer Stoltzfus is an adult individual residing at 1046 Newport Rd. Manheim PA 1754511. The DEFENDANT Calvary Church Member Mrs. Valerie Stoltzfus is an adult individual residing at 1046 Newport Rd. Manheim PA 17545 12. The DEFENDANT Calvary Church Member Mr. Gwen Smith is an adult individual residing at 21 Venture Dr. Holtwood PA 17532. 13. The DEFENDANT Calvary Church Member Mrs. Doug Smith is an adult individual residing at 21 Venture Dr. Holtwood PA 17532 14. The DEFENDANT Calvary Church Executive Pastor Mr. Brad Mullen is an adult individual with mailbox service at Calvary Church (address above).15. The DEFENDANT former Calvary Church Attendee Mr. Wesley Brooks is an adult individual residing at 28 1/2 Hummelstown Rd., Elizabethtown PA 17022 16. The DEFENDANT Calvary Church Attendee Ms. Lori Brunner is an adult individual residing at Millersville, PA 17551. 17. The DEFENDANT Calvary Church Attendee Ms. Linda LaCock is an adult individual residing at 965 Stone Hill Rd. Conestoga, 17516. 18. The DEFENDANT Calvary Church Chairman George Duff is an adult individual having a mailbox at Calvary Church Offices (address above). 19. The DEFENDANT Calvary Church Elder David Allen is an adult individual having a mail box at Calvary Church Offices (address above). 20. The DEFENDANT Calvary Church Elder John Beale is an adult individual having a mail box at Calvary Church Offices (address above). 21. The DEFENDANT Calvary Church Elder Dr. Joseph Calkins is an adult individual having a mail box at Calvary Church Offices (address above). 22. The DEFENDANT Calvary Church Elder Barry Ferguson is an adult individual having a mail box at Calvary Church Offices (address above). 23. The DEFENDANT Calvary Church Elder Kenneth Fry is an adult individual having a mail box at Calvary Church Offices (address above). 24. The DEFENDANT Calvary Church Elder Lee Hess is an adult individual having a mail box at Calvary Church Offices (address above).25. The DEFENDANT Calvary Church Elder Clair Hostetter is an adult individual having a mail box at Calvary Church Offices (address above). 26. The DEFENDANT Calvary Church Elder Walter Jackson is an adult individual having a mail box at Calvary Church Offices (address above).27. The DEFENDANT Calvary Church Elder Dr. Barry Keller is an adult individual having a mail box at Calvary Church Offices (address above). 28. The DEFENDANT Calvary Church Elder Donald Kitchen is an adult individual having a mail box at Calvary Church Offices (address above).29. The DEFENDANT Calvary Church Elder Donald Kliewer is an adult individual having a mail box at Calvary Church Offices (address above). 30. The DEFENDANT Calvary Church Elder Paul Lowery is an adult individual having a mail box at Calvary Church Offices (address above).31. The DEFENDANT Calvary Church Elder David Van Ormer is an adult individual having a mail box at Calvary Church Offices (address above). 32. The DEFENDANT Dr. Olaniyi Oluleye, also referred to as DEFENDANT DR OO is an adult individual having a residence at 497 Wheatfield Drive, Lititz, PA 17543 and having offices at 1120 Francis Ave., Lancaster, PA 17601. 33. The DEFENDANT Dr Amy Keefer is an adult individual receiving mail at Philhaven offices 352 East Main Street, Suite 100, Leola PA 17540 and/or Philhaven Hospital 283 South Butler Rd. Mt. Gretna PA 17064.34. The DEFENDANT Jeffrey Fiereck, Calvary Church’s legal counsel is an adult individual who resides at 4109 Forrest Rd. Mt Joy PA 17552. 35. The DEFENDANT Mr. Doug Hershberger is an adult individual having a mail box at Calvary Church Offices (address above).36. The DEFENDANT Mr. Gil Gregory is an adult individual having a mail box at Calvary Church Offices (address above). 37. The DEFENDANT Mr. Hale Johnson is an adult individual having a mail box at Calvary Church Offices (address above). B. FACTS 38. Paragraphs 1 through 37 are incorporated by reference as though set forth in full herein. 39. PLAINTIFF Bennett J. Vonderheide and the DEFENDANT Wendy Flanders have a minor child together out of wedlock; one Quinta Xavier Vonderheide (hereinafter referred to as QXV) age six, the matter of whose custody is and has been at all times relevant to this complaint, subject to the order of the court (SEE EXHIBIT A., Custody Order) currently in place. 40. DEFENDANT KY, DEFENDANT Johnny Miller, DEFENDANT Brad Mullen, DEFENDANT George May, DEFENDANT Todd Nathan, and DEFENDANT Attorney Jeffrey Feirick are or were employed by DEFENDANT Calvary Church while carrying out the actions herein identified and at all times relevant to this complaint. 41. That DEFENDANTS’ did act alone and in concert, as part of a conspiracy and individually to further a plan to alienate the PLAINTIFF father from his child, to falsely imprison the PLAINTIFF father by abuse of process and to enable the child’s DEFENDANT mother to gain sole custody of the child through any means. 42. That in the process of committing these actions and breeches of ethics the DEFENDANTS have caused irreparable harm to the PLAINTIFF, damaged his relationship with his minor son (QXV) and caused emotional distress by helping DEFENDANT WF to carry out actions listed and detailed herein against the PLAINTIFF father and his minor son against the orders of the court, various canon of ethics, state and local laws and the commonly accepted social behavior of decent human beings. 43. That the DEFENDANTS were part of an identifiable pattern and practice carried out by the DEFENDANT WF against two other fathers of two other children whom the DEFENDANT WF did bear and have out of wedlock prior to committing this same pattern of abuse against those fathers as well. 44. That this pattern of DEFENDANT WF appears pathological in nature and possibly indicative of mental health issues which are not being addressed by the DEFENDANTS in any way, and which mental health issues the DEFENDANTS have employed every possible manipulation and tactic to avoid the evaluation, recognition, admission and treatment of resulting in the damages hereby addressed. 45. That DEFENDANT CC and its counseling staff were not trained/qualified to recognize psychological problems in relation to DEFENDANT WF and her claims and further refused to accept, acknowledge and consider said conditions/problems when advised these mental health conditions existed and when they were provided evidence of same. 46. That DEFENDANT CC and its counseling staff were negligent in that they continuously fed into DEFENDANT WF’S imbalanced drive to get and maintain absolute control over the life of her minor son QXV through any means possible while damaging the life and reputation of the child’s father by any means possible as well and while refusing to acknowledge medical facts pertinent and intrinsic to DEFENDANT WF’S claims against the PLAINTIFF father to DEFENDANT CC and the courts. 47. That the DEFENDANT’S have engaged in a pattern of Parental Alienation Syndrome-like behavior which matches that described in EXHIBIT B., which states; a.) The Parental Alienation Syndrome (PAS) is the systematic denigration by one parent by the other with the intent of alienating the child against the other parent. The purpose of the alienation is usually to gain or retain custody without the involvement of the father. The alienation usually extends to the father's family and friends as well. . (SEE EXHIBIT B., PAS Article - A Guide To The Parental Alienation Syndrome) and EXHIBIT C. which states in part; “Any attempt at alienating the children from the other parent should be seen as a direct and willful violation of one of the prime duties of parenthood, which is to promote and encourage a positive and loving relationship with the other parent, and the concept of shared parental responsibility.” (SEE EXHIBIT C., Parental Alienation Syndrome: How to Detect It and What to Do About It). 48. That DEFENDANTS conspiratorial and individual actions did constitute numerous flagrant violations of Law and Ethics and that when taken as whole these actions do constitute a clear conspiracy and a pattern of illegal and unethical behavior whose only apparent end is to separate a minor child from his father against their will and the Orders of the Court. 49. That on November 17, 2004 at 11:38 a.m., DEFENDANT KY acting in her official position as counselor, a position of authority afforded her by DEFENDANT Calvary Church, and as point person for the co-conspirators, did write and cause to be delivered the e-mail attached as EXHIBIT D. (SEE EXHIBIT D., KY E-Mail) 50. That DEFENDANT KY, DEFENDANT Johnny Miller, DEFENDANT Brad Mullin, DEFENDANT George May and DEFENDANT Todd Nathan have never been accredited or licensed as counselors, in the Commonwealth of Pennsylvania as recognized by the State Board Of Social Workers, Marriage And Family Therapists And Professional Counselors (SEE EXHIBIT E., Pennsylvania State Code CHAPTER 49. LICENSURE OF PROFESSIONAL COUNSELORS) which holds State Licensed Counselors to very high and rigorous standards in the interests of protecting the public - none of which standards did the DEFENDANTS meet or even attempt to meet. 51. That the DEFENDANT CC did not require it’s counseling staff be licensed by the state nor that they take classes or courses required by the state to become licensed, or that they restrict their counseling and actions to those they are qualified for as evidenced by the fact that said counselors were not licensed and were in fact employed by DEFENDANT CC as counselors working at the DEFENDANT Church as counselors and did offer counseling services to people attending CC without a license from the Commonwealth. 52. That the DEFENDANT Calvary Church was in fact offering counseling services when at no time did it employ a licensed counselor. 53. Prior to Nov 17th, 2004 PLAINTIFF was told that the biased Church counseling staff was not counseling PLAINTIFF’S son as the PLAINTIFF had demanded and as had been repeatedly agreed to and affirmed by the DEFENDANTS. 54. On or around September, 2002, and in subsequent inquiries DEFENDANT KY did repeatedly deny to the child’s father, the PLAINTIFF in this case, ever treating the PLAINTIFF’S minor child QXV and stated clearly that she would not do so. 55. The DEFENDANT KY in her role as counselor did treat the PLAINTIFF’S minor son QXV while employed by DEFENDANT Calvary Church without a signed release or consideration of the PLAINTIFF/fathers rights, input or demands contrary to DEFENDANT’S repeated and assiduous denials of having ever done such (SEE EXHIBIT F., May 23, 2004 Memo from DEFENDANT Kathy Yoder to DEFENDANT George May and DEFENDANT Todd Nathan). 56. Upon learning of the DEFENDANTS actions in having treated the PLAINTIFF’S minor son, PLAINTIFF’S attorney requested DEFENDANT CC immediately provide PLAINTIFF with any and all records of his child’s treatment by unlicensed counselors at DEFENDANT CC (SEE EXHIBIT G., Letter to DEFENDANT CC from PLAINTIFF Attorney Longo). 57. The DEFENDANT KY claims that neither she nor any member of the DEFENDANT Church counseling staff kept any records of treatment or counseling for QXV contrary to ACA Code of Ethics, B.4. Records (SEE EXHIBIT H., ACA CODE OF ETHICS, Section B. 4.). 58. On December 7th 2004 DEFENDANT Church Chairman of Elders DEFENDANT George Duff wrote a letter on DEFENDANT Church stationary to PLAINTIFF’S attorney Longo stating that DEFENDANT CC had received, did in fact understand and would respond to the letter that PLAINTIFF’S attorney Longo had sent to DEFENDANT CC on November 22, 2004 by a date no later than January 15, 2005 (SEE EXHIBIT I., Letter To PLAINTIFF Attorney Longo From DEFENDANT CC Chairman of Elders DEFENDANT George Duff). 59. On January 5, 2005 DEFENDANT Jeffrey A. Feirick sent a letter to PLAINTIFF’S attorney Longo stating that; “There are no formal written records on Quinta Vonderheide at Calvary Church.” And including an enclosure which he purported to be the only record of the PLAINTIFF’S minor son QXV ever having been treated by DEFENDANT KY or anyone else at DEFENDANT CC (SEE EXHIBIT J. Letter to Attorney Longo from DEFENDANT Jeffrey A. Feirick and SEE EXHIBIT F. May 23, 2004 Memo from DEFENDANT Kathy Yoder to DEFENDANT George May and DEFENDANT Todd Nathan). 60. The DEFENDANT KY did refer the PLAINTIFFS son QXV to DEFENDANT DR OO for treatment at Philhaven Hospital without notifying, informing or requesting the input of the child’s father the PLAINTIFF in direct violation of the Custody Order (See EXHIBIT A., Custody Order). 61. That DEFENDANT DR OO did accept the referral of an unlicensed counselor with no academic or other qualifications or training and that DEFENDANT DR OO did proceed to treat a minor child while at no time prior to treating the minor child QXV did DEFENDANT DR OO have or request a release from the PLAINTIFF/father to treat the minor child QXV in direct violation of the Custody Order (SEE EXHIBIT A., Custody Order and SEE EXHIBIT K. Philhaven Evaluation). 62. The DEFENDANT KY did deny having any record of referring QXV to DEFENDANT DR OO in direct opposition and contrast to her responsibilities to her patient, the public, her employer and profession. (SEE EXHIBIT H., ACA CODE OF ETHICS, Section B. 4.) 63. DEFENDANT WF did at no time inform, explain, mention or request input from PLAINTIFF/father in regard to taking the minor child QXV to a psychiatrist (DEFENDANT DR OO) in direct violation of Court Orders (SEE EXHIBIT A., CUSTODY ORDER) knowing full well that the PLAINTIFF/father was vehemently opposed to QXV seeing any psychiatrist or counselor to whom his son was referred by DEFENDANT KY or in any way associated with DEFENDANT KY or DEFENDANT CC. 64. DEFENDANT DR OO did treat PLAINTIFF’S son QXV without a signed release from PLAINTIFF as required in direct violation of the Custody order (SEE EXHIBIT A., Custody Order). 65. DEFENDANT DR OO did prescribe “psychotropic” and mind altering drugs to PLAINTIFF’S minor son QXV without a signed release from PLAINTIFF as required in direct violation of the Custody order (SEE EXHIBIT A., Custody Order). 66. DEFENDANT WF did at no time inform, explain, mention or request input from PLAINTIFF in regard to his minor son being given “psychotropic” mind altering drugs by DEFENDANT DR OO, without a signed release from PLAINTIFF as required, in direct violation of professional ethics and Court Orders (SEE EXHIBIT A., CUSTODY ORDER). 67. DEFENDANT DR OO did fail to consult with or respond to PLAINTIFF about his actions regarding PLAINTIFFS son even after being contacted by PLAINTIFF/father in reference to his treating the PLAINTIFFS minor son QXV without a signed release from PLAINTIFF as required in direct violation of the Custody order (SEE EXHIBIT A., Custody Order). 68. PLAINTIFF contends that Section A: The Counseling Relationship and A.1. Client Welfare, The American Counseling Association Code of Ethics and Standards of Practice states as the very first words of the document that the; “Primary Responsibility". The primary responsibility of counselors is to respect the dignity and to promote the welfare of clients.” And that as opposed to following the words or the spirit of this directive DEFENDANT counselors have violated the dignity of the minor child QXV and the PLAINTIFF while taking actions which were clearly not in the best interests of the minor child involved in this case or his welfare in attempting to further a plan to separate that minor child (QXV) from his natural father, to alienate him from his father and to prevent him from seeing his father who loves him dearly and is authorized by the court to participate in his life as a matter of law. (See EXHIBIT H., The American Counseling Association Code of Ethics and Standards of Practice and SEE EXHIBIT A., Custody Order.) 69. It is the PLAINTIFF’S further contention that the course of action chosen by the DEFENDANT CC, DEFENDANT KY, DEFENDANT WF and other co-conspirators was the direct opposite of ethical directives from The American Counseling Association. The Association Guide to ethics above referred states that Counselors should seek; “Positive Growth and Development. Counselors encourage client growth and development in ways that foster the clients' interest and welfare; counselors avoid fostering dependent counseling relationships.” 70. The PLAINTIFF further contends that the Church and other DEFENDANTS did the exact opposite of what The American Counseling Association Guide to Ethics directs by actually moving the client and his mother to a house just thirty seconds away from DEFENDANT KY’s own home without notifying, informing or requesting the input of the child’s father the PLAINTIFF in this case in direct violation of the Custody order (SEE EXHIBIT A.) 71. That co-conspirators did plan and execute moving the child to a new home by coordinating the renting of a new home, moving all possessions a half an hour away from the child’s previous home (which was one minute away from the child’s father’s home) without notifying, informing or requesting the input of the child’s father the PLAINTIFF in direct violation of the Custody order (SEE EXHIBIT A., Custody Order). 72. That moving the child a half-hour away from his father’s home and into the direct control of DEFENDANT KY is consistent with a pattern of Parental Alienation Syndrome (SEE EXHIBIT B. & C., PAS). 73. This moving the child to a new home also entailed moving the child half an hour away from the only school he had ever known without notifying, informing or requesting the input of the child’s father the PLAINTIFF in this case in direct violation of the Custody order (See EXHIBIT A.). 74. The PLAINTIFF contends that the DEFENDANT Church and the other DEFENDANTS acted in direct opposition to the directives of the ACA Guide to Ethics in so doing as illustrated here “Family Involvement. Counselors recognize that families are usually important in clients' lives and strive to enlist family understanding and involvement as a positive resource, when appropriate.” 75. The PLAINTIFF contends that the DEFENDANT CC, DEFENDANT WF and DEFENDANT KY engaged in a pattern that was deceptive and contra indicated by all medical and psychological literature referencing the positive counseling treatment and care for children in custody settings and which patterns and action are clearly negligent in as much as they are constituent of a conspiracy and that each of the DEFENDANTS is culpable and an active participant in a pattern and practice of deception, manipulation and wrongful treatment in violation of PLAINTIFF and his son’s rights and court orders. 77. PLAINTIFF Bennett J. Vonderheide in his capacity as pro se representative seeks redress for actions taken by the DEFENDANT against his own interests and those of his minor son Quinta Xavier Vonderheide. 78. PLAINTIFF Bennett J. Vonderheide in his capacity as pro se representative hereby brings suit against DEFENDANT CC, DEFENDANT CC pastors, DEFENDANT CC Elders, DEFENDANT CC Counseling Staff, certain DEFENDANT CC members and DEFENDANT CC attendees and the adult DEFENDANT mother and DEFENDANT daughter (and half sister to QXV) DEFENDANTS Ms. Wendy Flanders and DEFENDANT Ms. Emily Flanders herein named as DEFENDANTS for their parts individually and collectively in the aforementioned conspiracy and assault against himself and his minor child Quinta Xavier Vonderheide. 79. PLAINTIFF Bennett J. Vonderheide contends the DEFENDANTS have planned, engaged in and carried out a pattern, campaign and conspiracy constituting and including but not limited to defamation, abuse of process, false arrest, alienation of affection, negligence, intentional infliction of emotional distress, denial of parental rights, harassment, harboring, interference with court orders, obstruction of justice and breach of confidentiality against PLAINTIFF and his minor child Quinta Xavier Vonderheide. 80. PLAINTIFF
contends that part of said pattern specifically matches those actions
described in medical literature and law as Parental Alienation Syndrome
as described in EXHIBIT B.; 81. The DEFENDANT’S conduct is willful, intentional, unprivileged, has caused and is causing irreparable harm as well as monetary damages to PLAINTIFF while causing lifetime damage to the child; damage that needs to be stopped immediately and reversed in the interest of allowing the child an opportunity to live a normal life and all that he has a right to. C. COUNT I DEFAMATION82. Paragraphs 1 through 81 are incorporated by reference as though set forth in full herein. 83. PLAINTIFF submits DEFENDANT KY’S e-mail (SEE EXHIBIT D.) and PLAINTIFF contends this email clearly demonstrates and is indicative of the pattern of defamation which has been the practice of DEFENDANTS in matters concerning PLAINTIFF Mr. Vonderheide and his minor son Quinta Xavier Vonderheide (QXV). 84. That said email contained the following defamatory statements which demonstrate precisely but not totally (as stated in email - “only the tip of the iceberg”) what the DEFENDANTS have been saying and spreading throughout the community about PLAINTIFF over the past three years and to many individuals influencing the minor child QXV. “I basically ignored it until he threatened to kidnap my daughter.” “Ben does not allow Quin to do normal things when he is with him.” “Ben sometimes does not feed Quin.” “Ben has told Quin outlandish things – the weekend they moved was Ben’s weekend – he told Quin – Your mom is moving and she isn’t coming back for you.” “Ben didn’t allow Quin to go to his school orientation this year in September.” “It was on a Tuesday night he didn’t let Quin play baseball this summer on the Saturday mornings that he had Quin.” “Ben has been telling Quin that he is in a “stupid” school and that he isn’t going to go there anymore and the kids are “stupid”.” “Ben kept Quin this summer and he was not going to return him” “Of course this is only the tip of the iceberg.” “I am also a mandated reporter and Quin’s situation has, several times been a huge concern to me.” “You and I both know how difficult it is for a child who is suffering emotional abuse and yet how hard it is to prove such a thing.” “He is not a safe person.” “He will not take a drug test and took the 5th when asked under oath if he does drugs.” “Ben’s history and my own personal experience lead me to believe that Ben is not safe around children.” “I want you to be warned of the situation as it is a difficult one and not probably as it appears.” “Ben can be very charismatic and say all the right things.” “He is a very manipulative person.” 85. That on March 13th 2005 DEFENDANTS did attempt to have PLAINTIFF arrested and did have PLAINTIFF escorted from the Church building and harassed by the police simply for coming to worship at a regularly scheduled Sunday service at DEFENDANT Calvary Church sanctuary. 86. PLAINTIFF had been invited by and was seated with a 37-year member of the DEFENDANT Church. PLAINTIFF had caused no conflict, disturbance or other action to warrant said police harassment. 87. That the DEFENDANTS had the police officer await PLAINTIFF immediately outside of the sanctuary doors and within the hallways of the Church building. 88. That the DEFENDANT CC did arrange for said officer who then attempted to entrap PLAINTIFF into an arrest. 89. And that when this attempted entrapment did fail the police officer did physically remain close to PLAINTIFF and did follow/escort PLAINTIFF out of the CHURCH building in front of the entire congregation. 90. This action defamed the PLAINTIFF in front of many hundreds of Church attendees. 91. Said actions by the police officer and DEFENDANTS did cause a terrible impression to be left upon the entire congregation that PLAINTIFF was a dangerous man who needed to be removed from the Church to keep the parishioners and especially the children safe from PLAINTIFF. 92. PLAINTIFF contends that these actions were intended to damage the reputation, good name and standing of PLAINTIFF Mr. Vonderheide in the community and especially to his son QXV. 93. PLAINTIFF further contends that these actions began well before this incident and continued long after this letter (SEE EXHIBIT D., KY E-Mail) to PLAINTIFF’S minor son’s new principal had been provided to the top leaders of DEFENDANT CC with a request that they take action to stop said slander and defamation. 94. DEFENDANT KY was still employed as a counselor by DEFENDANT Calvary Church long after this letter was provided by the PLAINTIFF to her employers at Calvary Church. 95. DEFENDANT CC did in fact not fire DEFENDANT KY or otherwise terminate her employment on the occasion of this e-mail but did in fact continue to employ DEFENDANT KY until the DEFENDANT KY resigned four (4) months later in March, 2005. 96. PLAINTIFF alleges that this four (4) month period of continuing employment of DEFENDANT KY by the DEFENDANT CC is further evidence of the DEFENDANT CC’s pattern of abuse, defamation and sanction against PLAINTIFF Vonderheide and that actions of co-conspirators was and is Church approved from the top level of authority and decision making. 97. PLAINTIFF contends that this four (4) month period is evidence of complicity of the DEFENDANT KY’S employer DEFENDANT CC and it’s executives in fostering, furthering and prolonging a pattern of defamation and Parental Alienation Syndrome perpetrated by KY and the other defendants in this case. 98. This four (4) month period of continued employment allowed DEFENDANT KY continued access to PLAINTIFF Vonderheide’s minor son and to other Church attendees who were directly influenced by KY in her ongoing campaign of abuse and defamation aided, abetted and paid for by the Church. 99. Further evidence will prove that these types of malicious, sneaky, manipulative and deceitful behavior were not one isolated instance but rather that this was the standard for dealings involving the PLAINTIFF Mr. Vonderheide and his son by employees, members and representatives of DEFENDANT CC over a three year period. 100. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 101. That said actions are willful, wanton and deliberate and constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. 102. Paragraphs 1 – 101 are incorporated by reference as though set forth herein 103. That DEFENDANT KY acting in her official position as counselor at DEFENDANT Calvary Church and as ‘point-man’ for the co-conspirators did treat/counsel and arrange for others to treat/counsel the minor child QXV without a release from PLAINTIFF. 104. PLAINTIFF further contends that DEFENDANTS surreptitious and deceptive tactics used in lying to the child’s father about her counseling his son were further evidence of KY’S participation in a pattern of breach of confidentiality on all levels and is behavior similar to that described in literature on Parental Alienation Syndrome (SEE EXHIBIT B., PAS). 105. That in said treatment DEFENDANT KY and other DEFENDANTS did solicit, gather, bias, falsify and then dispersed private and personal information to many various known and unknown individuals, officials, ministers, etc about said minor child without the written release from PLAINTIFF as is required as normal practice by professional standards of ethics and as is additionally in keeping with the parental rights specified within custody order (SEE EXHIBIT A.) and within the guidelines of common decency, privacy and sense as well as the ACA Code of Ethics and Standards for Practice “Section B: Confidentiality” which states in section “B.1., Right to Privacy, Respect for Privacy.” that; “Counselors respect their clients’ right to privacy and avoid illegal and unwarranted disclosures of confidential information.” (See EXHIBIT H., ACA Code of Ethics and Standards for Practice) and that DEFENDANT KY’s actions were indeed in the words of the ACA Code of Ethics “illegal and unwarranted disclosures of confidential information.” 106. That on or about July of 2004, DEFENDANT KY acting in her official position as counselor and as ‘point-man’ for the co-conspirators did refer the minor child QXV to DEFENDANT DR OO of Philhaven Hospital without authorization or release from the father (EXHIBIT K., Treatment documents from Philhaven DEFENDANT OO). 107. That said referral is illegal and a breach of confidentiality in that DEFENDANT KY has no right discussing anything whatsoever about the minor child without signed releases in place. 108. That said referral provides further evidence of the DEFENDANT KY acting in a coordinated effort with her superiors and employer DEFENDANT CC to enact a state of alienation between PLAINTIFF father and his minor son. 109. That DEFENDANT KY acting in her official position as counselor and as ‘point-man’ for the co-conspirators did further participate in maligning PLAINTIFF/father unknowingly to agree to allow DEFENDANT Dr. Amy Keefer to counsel QXV under the guise that the said counseling was completely independent and not biased by any DEFENDANT CC influence. 110. That in fact DEFENDANT DR OO is or was a DEFENDANT CC attendee at the time that DEFENDANT KY referred the PLAINTIFF’S minor son QXV to him for psychiatric treatment without a release from the child’s father as per custody order (SEE EXHIBIT A.) and standard operating procedure in a case involving shared custody of a minor child. 111. That in fact DEFENDANT DR OO had already treated and drugged the child (approximately six months prior) under the auspices of Philhaven Psychiatric Hospital completely unbeknownst to PLAINTIFF/father and in support of the ongoing conspiracy and campaign coordinated by DEFENDANT CC. 112. That DEFENDANT DR OO had then referred QXV to DEFENDANT Dr. Keefer without PLAINTIFF/fathers involvement or knowledge and in an effort to make it appear as though PLAINTIFF/father was being allowed to participate according to his rights and that treatment, counseling and drugging was in keeping with the court orders and ethical practice. (EXHIBIT L., Treatment documents from DEFENDANT Philhaven Dr. Amy Keefer). & (SEE EXHIBIT N., The Principles of Medical Ethics With Annotations Especially Applicable to Psychiatry 2001 Edition, Section 2) 114. That DEFENDANTS then attempted to have PLAINTIFF/father sign a release for child to be treated by DEFENDANT DR OO as if it were the first time he were treated by DEFENDANT DR OO (SEE EXHIBIT M., Release Request Documents From Philhaven). 115. That these actions of breach of confidentiality were designed to get PLAINTIF/father to sign a release allowing ongoing treatment, counseling and drugging being staged, scripted and manipulated by DEFENDANTS to negatively control minor child QXV and impact his current custody proceedings. 117. That the PLAINTIFF/father could have protected his son and that all the illegal treatments, counseling and drugging would have never happened if; the DEFENDANTS did not willfully and specifically violate confidentiality concerning the minor child QXV, willingly and completely deceiving the child’s father about the most important matters in his minor child’s life breaching his basic human and civil rights. 118. That DEFENDANT KY acting in her official position as counselor and as ‘point-man’ for the co-conspirators did further share confidential information about the minor child QXV with numerous others at Calvary Church including but not limited to the other members of the counseling staff, ministers, operations individuals, Church members, attendees, and others to be identified through discovery, in a concerted effort to enlist their support in assaulting the PLAINTIFF as identified within this suit. 119. That said sharing of information is illegal and a breach of confidentiality in that KY has no right discussing anything whatsoever about the minor child without a signed release from the father as per standard operating procedure and the Custody Order concerning the medical treatment of minor child QXV (SEE EXHIBIT A). 120. That because the DEFENDANT Church which hired, trained and employed DEFENDANT KY for years as a counselor never required DEFENDANT KY to become a licensed counselor the DEFENDANT Church did thereby negligently support, facilitate, make possible and encourage the abhorrent lack of professionalism exhibited by the counseling staff and the DEFENDANT KY in breaking confidentiality. 121. That DEFENDANT KY acting in her official position as counselor for DEFENDANT Calvary Church and as point for the co-conspirators did further share confidential information about the minor child QXV with the child’s school principal, teacher and others from the “two room schoolhouse” setting where she had moved the child as proven by DEFENDANT KY’S e-mail sent to principal (EXHIBIT D). 122. That said sharing of information is illegal and a breach of confidentiality in that DEFENDANT KY has no right discussing anything whatsoever about the minor child without a signed release from the father as per standard operating procedure and Custody Order concerning the medical treatment of minor child QXV (SEE EXHIBIT A) 123. That the DEFENDANT’S words, actions and manner of speaking as revealed in the DEFENDANT KY’s e-mail to the minor child QXV’S principal (SEE EXHIBIT B) are diametrically opposed to all recognized, professional and even the most basic general, public standards of conduct with regard to confidentiality, decency and integrity. 124. That an unknown number of DEFENDANT CC staff, ministers, members and attendees have been spreading false stories and information about the child and PLAINTIFF created during, by and as a direct and intended result of DEFENDANT KY’s breach of confidentiality combined with illegal counseling of the minor child QXV. 125. From a date on or about September, 2002 until on or about November 20, 2004 DEFENDANT KY individually and with the support of DEFENDANT CC and all co-conspirators has lied, obfuscated the truth and changed her answers to basic questions pertaining to her counseling of the minor child QXV such as when and if she is treating/counseling him, etc, in a direct and concerted effort to circumvent the ethics of counseling in general and confidentially in specific. 126. DEFENDANT KY in her position and authority at DEFENDANT CC has stated the following at different times depending on what was convenient. • “I
am Counseling WF but not the child QXV” (to PLAINTIFF) 127. That DEFENDANT KY apparently claims that when she is defaming and slandering the PLAINTIFF and assisting in her part of the PAS (SEE EXHIBIT B. & C., PAS) she is acting as a friend. Yet when she has the opportunity to assist the illegal interference by working with doctors, lawyers, principals, police, etc she makes reference to her being a professional counselor treating the child and having credentials to tell these other professionals that PLAINTIFF is the source of all the child’s problems and she knows from her counseling etc and due to her experience. 128. That the DEFENDANT KY has broken the confidentiality of minor child QXV in that she admits to counseling the child in email to principal (SEE EXHIBIT D.) to give credence and a professional level of truth and experience to her claims and then states specific details which are protected by standard and accepted rules of confidentiality. 129. Thus DEFENDANT KY has a responsibility, liability and ethical requirement to remain non-friends with WF and/or stop counseling and having a confidential relationship with the minor child QXV and to keep all her personal and professional opinions to herself. 130. PLAINTIFF submits the following excerpts from EXHIBIT D., KY email sent to the Principal of QXV’S school which demonstrates the sharing of confidential (yet not truthful) information as a professional and without signed release in place. “I have
counseled for twenty years” 131. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 132. That said actions are willful, wanton and deliberate and constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. 133. Paragraphs 1 through 132 are incorporated by reference as though set forth in full herein. 134. That the DEFENDANTS did strategize, orchestrate and carry out a conspiracy to abuse the legal process for the purposes of interfering with the custody and parenting rights of PLAINTIFF and in so doing have caused massive interference in the custody rights of PLAINTIFF and brought extreme destruction and damages to the PLAINTIFF and his son, their personal life, PLAINTIFFS personal and business reputation and their emotional health and quality of life. 135. PLAINTIFF contends that DEFENDANTS as a group and individually have acted alone and in concert to produce a pattern of abuses which constitute Abuse of Process and which are part and parcel of the pattern of Parental Alienation Syndrome enacted by the same group at the same time against the same two people, namely; the PLAINTIFF and his minor son QXV (SEE EXHIBIT B. & C., PAS). 136. PLAINTIFF submits EXHIBIT O., Abuse of Process Timeline which chronicles the specific actions, accusations, charges and abuse of process carried out by DEFENDANTS as a pattern, with strategic foresight and without cease for over three years (SEE EXHIBIT O. Abuse of Process timeline). 137. In addition That DEFENDANT Calvary Church through it’s team leader KY did attempt to have PLAINTIFF arrested on Easter Sunday of 2004 by falsely claiming PLAINTIFF had allegedly threatened to kidnap a child. 138. That on November 10, 2004 DEFENDANTS KY & TY did attempt to have PLAINTIFF arrested for his phone number appearing on their caller ID. DEFENDANTS KY & TY misrepresented the facts of where and why the call had occurred to police officer in an attempt to have PLAINTIFF falsely arrested. 139. That on or about January 9, 2005 DEFENDANTS KY & TY did attempt to have PLAINTIFF arrested for serving them with a subpoena to testify. 140. That on March 13, 2005 DEFENDANTS did attempt to have PLAINTIFF arrested and hauled away in handcuffs simply for coming to worship at DEFENDANT Calvary Church sanctuary. 141. That the DEFENDANT conspirators did utilize the third falsely filed PFA (dated September 22, 2004) against PLAINTIFF to attempt to establish an eighteen-month period of removal of father from contact with the child in synch with move to one room schoolhouse with DEFENDANT KY’s daughter and influence present and strong. Said PFA filed by DEFENDANT WF was thrown out after a full hearing in the court of Judge Workman in Lancaster County, PA. 142. That as recently as April 19 th through April 27th, 2005 DEFENDANT WF again has police completing a warrant to arrest PLAINTIFF for another set of false accusations under indirect criminal contempt law. [NOTE: PLAINTIFF arrested and found innocent again by May 2nd, 2004] 143. That DEFENDANTS as demonstrated by history are currently planning the next assault through the misuse and abuse of the legal system and will continue to carry out these assaults and abuses until forced to stop by the courts through this action of suit. 144. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 145. That said actions are willful, wanton and deliberate and constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. COUNT IV ALIENATION OF AFFECTIONS 146. Paragraphs 1 through 145 are incorporated by reference as though set forth in full herein. 147. That actions herein described in sections identified as defamation, breech of confidentiality, abuse of process, negligence, violation of court orders relating to Quinta Xavier Vonderheide and obstruction of justice are all components of Parental Alienation Syndrome (a form of emotional child abuse) and are intended to cause Alienation and hatred of the PLAINTIFF by his son (SEE EXHIBIT B. & C., PAS). 148. PLAINTIFF submits EXHIBIT P., DEFENDANT KY DEFENDANT CC and DEFENDANT CC Interactions Timeline further illustrating the patterns and practices in evidence (SEE EXHIBIT P., DEFENDANT KY, DEFENDANT CC and DEFENDANT CC Interactions Timeline) for the review of the court as the timeline clearly indicates the pattern of abuse suffered by the PLAINTIFF and his minor son as a direct result of the actions of the DEFENDANTS. 149. The PLIANTIFF further contends that this timeline in combination with the Abuse of Process Timeline already submitted and a third set of date related facts and observations entitled “Quinta Quotes” will provide the court with an even more clear view of the effects of the patterns and practices of the DEFENDANTS in this case on the minor child QXV. (SEE EXHIBIT Q., Quinta Quotes). 150. DEFENDANTS did intentionally strategize and effect the physical moving of the child QXV against the fathers rights (SEE EXHIBIT A) and in a pattern designed to remove the child completely from the father and his family, friends, business associates and contacts forever. 151. That the conspirators did illegally, with intent and malice move the child without sufficient notice to father and without fathers input (again against court order) and into a new home less than thirty seconds distance from the lead representatives for DEFENDANT Calvary Church i.e. DEFENDANT KY and into a one room “Amish” style schoolhouse environment where the DEFENDANT KY’s child did and had attended for years prior. 152. That the DEFENDANTS did effect said physical moving of the child to the control zone of DEFENDANT KY so as to further DEFENDANT KY and all co-conspirators cult-like domination and direction of the child’s thought process and life completely and specifically away from PLAINTIFF, (child’s father), his friends, relatives, associates and all individuals that are not a part of said cult-like group. 153. That the conspirators did refuse to provide accurate information to the new school about the child’s father/PLAINTIFF but did instead begin a campaign of slander and defamation and warning against the PLAINTIFF. 154. That when PLAINTIFF pierced this mirage through winning the PFA and contacting and impressing the school personnel that DEFENDANT KY did put into writing (SEE EXHIBIT D., KY E-Mail) of the false slanderous and defamatory statements she and the co-conspirators had been perpetrating against the PLAINTIFF constantly over a period of three years and which demonstrate a pattern of alienation of father from the child’s life. 155. The primary representative of the co-conspirators and official representative of Calvary Church throughout this process DEFENDANT KY did then cause said letter to be sent via electronic email to the principal of the child’s school (SEE EXHIBIT D., KY E-Mail) in an attempt to rescue the failed strategy of alienation. 156. That the DEFENDANT Church and related co-conspirators have caused the child to refuse his fathers/PLAINTIFF’S sir Name as his own as a method of furthering their alienation goals as illustrated in the document herein entitled “Quinta Name Game” and listed here as EXHIBIT R. (SEE EXHIBIT R., The Name Game & SEE ALL EXHIBIT VITH A NAME LISTED) 157. That the co-conspirators refused to follow Judge Perezous’ Order specifically directing for the change of name back to his original “QXV” (SEE ALL EXHIBIT VITH A NAME LISTED and EXHIBIT T. Judge Perezous’ Order). 158. That the DEFENDANTS continue to refuse to use the child’s correct name throughout the child’s DEFENDANT CC “church” experience which does constitute the vast majority of the child’s time other than school. 159. That during the remainder of the time in child QXV’S life outside of these two areas (school and Church) he is constantly near or in the control of DEFENDANT KY and the co-conspirators who are concertedly brainwashing the child to eliminate his correct last name and his connection to his father PLAINTIFF and all his paternal ancestors and relatives. 160. That DEFENDANTS have emotionally, spiritually and at times physically abducted &/or harbored the child from the PLAINTIFF father in contempt of court orders for as long as five and one-half months at one time thus producing intense and constant, uninterrupted alienation. 161. That whenever child QXV returns from these times of being stolen from his father he is always distant, angry and alienated from his father until healing of these actions can take hold and help the child overcome the brainwashing and terrible psychological poisoning against his father carried out by DEFENDANTS. 162. These concerted efforts by co-conspirators have resulted in extreme disruption, ruination and destruction of all aspects the PLAINTIFFS life, the minor child QXV’S life and the elimination of a potential to reconcile or engage in a less traumatic breakup with what had been the PLAINTIFF’S family. 163. That the DEFENDANTS have carried out a campaign of brainwashing and mind poisoning intending to be extremely damaging to the relationship between father PLAINTIFF and his minor son QXV. That the DEFENDANTS have conducted this campaign under the guise of counseling. 164. That said campaign has resulted in ongoing interference with normal father child growth, health and relationship and is evidenced in the statements made by the minor child QXV (SEE EXHIBIT Q., Quinta Quotes). 165. That said brainwashing and alienation will potentially cause the child QXV to hold a horrible impression of fathers (his own father and others) and an unhealthy opinion that dominant, deceitful women are to decide, rule and control all aspects of a child’s life and the fathers life 166. That this imbalanced control and brainwashing will potentially cause irreparable damage to the child and affect his relationships and ability to be a father and have his own family when he grows to adulthood. 167. That DEFENDANTS have led the child to be absolutely confused by aligning the word of Jesus and God as selectively and beguilingly pulled from Biblical scripture into making him believe his mother (DEFENDANT WF)’S and the other DEFENDANTS lies as being the true reality of events and the works of God and Jesus. 168. These actions by the DEFENDANTS include telling the child lies about his father, the PLAINTIFF in this case, that the PLAINTIFF/father has done horrible things and that his father is going to Hell. 169. These same DEFENDANTS have consistently represented to the minor child QXV that his mother (DEFENDANT WF) is honest, a victim of the PLAINTIFF’S actions and is going to heaven. 170. That said actions have enabled, enhanced, furthered and fully supported DEFENDANT WF’S disorders and dysfunction (especially the denial symptom identified in all of DEFENDANTS WF’S medical/mental and emotional diagnoses) and has set the child up to follow the dysfunctional, deranged and awful patterns which constitute the DEFENDANT WF’S entire life, all day, every day and have for many years. 171. That DEFENDANT KY conspiring with others did develop and implement a plan to move a minor child and his family to a “one-room schoolhouse where she has a child is beyond bizarre from the standpoint of a counseling professional exceeding the appropriate bounds of the client counselor relationship. i. Said school has 14 total students (grade 1-4) sharing one room and one teacher. ii. DEFENDANTS Mr. & Mrs. Yoder’s child is amongst these children. iii. DEFENDANTS Mrs. & Mr. Yoder are extremely active and present on a day to day basis within this “one-room schoolhouse” setting. DEFENDANTS Mrs. & Mr. Yoder utilize the aforementioned facts in a perfect position to further promote PAS. (SEE EXHIBIT B & C., PAS). 172. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 173. That said actions are willful, wanton and deliberate and constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. 174. Paragraphs 1 through 173 are incorporated by reference as though set forth in full herein. 175. DEFENDANT Calvary Church (CC) stands out in culpability in that the PLAINTIFF in this case has taken every possible step to inform, advise and alert the Church itself through all means possible, over a period of three years. Specifically the PLAINTIFF has informed DEFENDANT Church authorities beginning with DEFENDANTS KY and DEFENDANT George May and then informing DEFENDANT Todd Nathan, Brad Mullin, Johnny Miller, all the elders, etc. at each step asking each of these Church employees, members authorities and representatives to stop the abuse. 176. PLAINTIFF has advised these individuals of DEFENDANT WF’S documented pattern, history and diagnoses and has provided these DEFENDANTS overwhelming evidence to support the fact that DEFENDANT CC has done and continues to do extensive and life-altering harm and damage to the child QXV to the PLAINTIFF, her other children and herself. 177. That time and again the DEFENDANT CC has told the PLAINTIFF that the DEFENDANT CC would in fact “investigate” the actions of the DEFENDANT CC (SEE EXHIBITS J. and K.) and that throughout the entire three years of assault, defamation lies and abuse suffered by the PLAINTIFF and his minor son QXV at the hands of the DEFENDANTS the PLAINTIFF has remained interested in and has actively sought to resolve these matters by any other means within the law as demonstrated in his attorney’s letter to DEFENDANT Brad Mullin dated December 21, 2004. (SEE EXHIBIT S. Letter to DEFENDANT Brad Mullin from PLAINTIFF Attorney Longo) and all other attempts to gain truth, action and resolve. 178. That throughout this entire process and to this day the DEFENDANT CC has continued its assault as detailed herein, in an unabated manner, with intent, malice, forethought and systematic dogmatism as evidenced by their most recent attempt to have PLAINTIFF arrested for simply coming to Church at Sunday Worship. 179. DEFENDANT CC through their employee Todd Nathan (and others) were approached, advised, informed, alerted, provided evidence from and called to correct these egregious actions by Mr. John Harris who is the father of the minor child of DEFENDANT WF’S second child also born out of wedlock, whose name has been changed numerous times and who has been the subject of the exact same pattern of abuse exhibited and detailed herein by DEFENDANT WF and DEFENDANT CC staff members. 180. Mr. Harris’ attempts to inform the DEFENDANT Church of these actions, along with his willing participation in their “peacemakers program” and events began in Spring 2004 and did continue until said father gave up all rights to see his child and gave complete control to the DEFENDANT Church and DEFENDANT WF as a result of the DEFENDANTS constant abuse, harassment and litigation in a pattern near identical to the one detailed herein and executed against the PLAINTIFF. 181. DEFENDANT CC was also approached, advised, informed, alerted, provided evidence from and called to correct these egregious actions by DEFENDANT CC members in good standing, various DEFENDANT CC elders and the DEFENDANT CC member Jerry Fry the father of DEFENDANT KY during this period. 182. That upon realizing the utter futility of trying to communicate with DEFENDANT CC directly, PLAINTIFF requested that a 37 year church member intercede with the DEFENDANT CC on PLAINTIFFS behalf and explain to DEFENDANT CC that the PLAINTIFF is a sane, loving father who merely wants what is best for his son the minor child QXV. 183. The DEFENDANT Church and its leadership were wholly uninterested in hearing the facts of this case and instead became hostile towards the 37 year Church member, rebuking him for his input. 184. Said 37 year Church member then requested a specific Church Elder get involved in this case and that this Elder try to help settle the matters involved. 185. Said DEFENDANT CC Elder did then complete an extensive investigation and bring these matters and evidence to the DEFENDANT Church board in an attempt to resolve these matters. 186. The DEFENDANT Church board then brought false accusations against their said DEFENDANT Church elder forcing him to resign. 187. Upon the Church demonstrating they would deny, deceive and manipulate the truth to their unbalanced, biased and spiritually sick beguiling no matter who tried to help them to correct their actions PLAINTIFFS counsel Lucile Longo wrote a letter to the DEFENDANT CC (SEE EXHIBIT G., Letter to DEFENDANT George Duff at DEFENDANT CC from Lucile Longo) November 22, 2004 again asking them to please consider the matter in light of the best interests of his minor child QXV and notifying CC that legal action was to follow if they did not immediately correct their egregious actions against PLAINTIFF and the minor child, PLAINTIFF’S son QXV. 188. On December 7, 2004 and in response to the PLAINTIFFS letter (SEE EXHIBIT G., Letter to CC from PLAINTIFF) the DEFENDANT CC wrote a letter to the PLAINTIFF saying they would get back by January 15, 2005 (SEE EXHIBIT I., 12.04 Elder George Duff's Letter to Attorney Lucille Longo) no response has been forthcoming. 189. At or about this time the DEFENDANT Church did employ to it’s service a “reported” former Judge Advocate General, DEFENDANT Jeffrey Feirick, in the DEFENDANT Church’s alleged Investigation into all facts of case (SEE EXHIBIT J., Letter from DEFENDANT Calvary church and EXHIBIT F., memo from DEFENDANT KY.) 190. PLAINTIFF has just been informed there are results of this alleged investigation by the DEFENDANT Church of the DEFENDANTS actions, results of the alleged investigation have been in possession of the DEFENDANT Church for months. 191. Said results of the alleged investigation have been withheld from PLAINTIFF and his contacts at DEFENDANT CC. 192. PLAINTIFF has requested a copy from DEFENDANT Jeffrey Feirick on April 19th 2005 and been refused. 193. At or about this time or some time after the appointment and alleged investigation by the reported former JAG investigator the DEFENDANT CC Church board did appoint a group of 3 elders in an Ad hoc committee to investigate all of the facts of this case. 194. The results if any in fact do exist of this separate investigation by the DEFENDANT Church into the actions of the DEFENDANTS have never been shared with the PLAINTIFF or his contacts at the DEFENDANT Church. 195. In the middle of DEFENDANT WF filing yet another fraudulent and false Protection from Abuse Order (false PFA #3), (SEE EXHIBIT O.) moving the child, filing three false Indirect Criminal Contempt Charges and while conducting the campaign of defamation and PAS detailed herein against the PLAINTIFF and father of her only son, DEFENDANT CC rewarded DEFENDANT WF by exalting her as a born again Christian and granting her full Church membership (approximately November 2004). 196. DEFENDANTS were negligent in that they treated the child at all without authorization and written release from the PLAINTIFF as per common professional, ethical and legal practice demands and in direct violation of the spirit and the letter of the Custody order concerning this child the minor QXV (SEE EXHIBIT A). 197. DEFENDANTS were negligent in that they treated the child after developing a very close personal relationship with Wendy Flanders (particularly DEFENDANT KY) in direct violation of the ACA Code of Ethics and Standards for Practice (See EXHIBIT H.). 198. DEFENDANTS were negligent in that no one on the counseling staff is or was ever qualified to treat DEFENDANT WF due to her specific psychological, emotional and physical conditions and special needs. 199. DEFENDANTS were negligent in that they referred the minor child QXV for psychiatric care without having held the proper credentials to do so as the DEFENDANTS have no certification, experience or credentials, which qualify them to recommend any patient for psychiatric care or drugging. (SEE EXHIBIT E.) 200. DEFENDANTS were negligent in that they did directly assist and enable DEFENDANT WF in her deceitful and diabolical actions even after being informed by numerous individuals of DEFENDANT WF’S patterns and practices as the DEFENDANTS appear to believe that DEFENDANT WF is “born again and saved by Jesus” and is above the psychological, emotional and physical conditions which she has suffered from and has been diagnosed with for more than a decade. 201. DEFENDANTS were negligent in that DEFENDANTS did ignore their own observations and claims when these observations and claims did not fit their plan “to take the child away from his father” as evidenced below in this excerpt from EXHIBIT D, DEFENDANT KY’S E-mail to Principal Colleen Pavlovec in which DEFENDANT KY touches on the fact the DEFENDANT WF has serious mental health problems and indicates that DEFENDANT KY is aware that DEFENDANT WF has various mental and physical limitations and requires help from DEFENDANT KY with strategies and the direction of actions in order to carry out what would be normal behaviors and day to day living for average or “untroubled” individuals. “I talked to Wendy this morning and I have been working with her on strategies and working with other people.” “She was involved in a horrific car accident a number of years ago where the steering wheel was imbedded in her chest and the front of her face was ripped off.” “She experiences pain all of the time.” “It will never get better.” “She had some neurological damage that has not affected her IQ but it does cause her to use some channels of communication that are more familiar to her”. “We have been discussing how to talk to people when she feels the stress so that she doesn’t come across the wrong way.” “She has made great strides.” “But she will be the first to admit she has a long way to go.” 202. Negligent actions of DEFENDANTS have caused irreparable damage and loss to PLAINTIFF and in fact have caused and continue to cause further damage to DEFENDANT WF and all others involved by not directing DEFENDANT WF to seek and follow professional help as she desperately needs as her continued acrimonious and bellicose behavior toward the PLAINTIFF demonstrates. 203. On July 23rd, 2004 DEFENDANT WF (in collusion with her friend and Church Counselor DEFENDANT KY) willfully, unilaterally and in direct opposition to the court order, the best interest of the child and the request of the PLAINTIFF father, did take the child Quinta Xavier Vonderheide to a psychiatrist and hospital for evaluation, treatment and manipulation by DEFENDANT OO (SEE EXHIBIT K.). 204. DEFENDANTS were extremely negligent in that they referred the minor child QXV to be drugged by another CC attendee DEFENDANT Dr. OO and in so doing risking the child’s life and bypassing the child’s normal caregivers and other professionals in an attempt to help DEFENDANT WF gain further advantage in court of custody as demonstrated by the facts below and as demonstrated by the misinformation and lies incorporated by DEFENDANT WF into the report by DEFENDANT OO (SEE EXHIBIT K.). 206. DEFENDANT willfully took the child to Philhaven and to a Psychiatrist who attends the same church as PLAINTIFF requested the child be removed from the influence of I.E. DEFENDANT Calvary Church. 207. DEFENDANTS willfully misrepresented facts and created false detail to produce a diagnosis, treatment and prognosis to be used as a tool in custody dispute only. Evaluations and Subsequent Reports). 208. DEFENDANTS willfully avoided requesting the input of all persons of credibility in the child’s life who would disagree with the DEFENDANTS fraudulent claims and the conspiracy of actions detailed herein. 209. In specific DEFENDANTS ignored all normal entrée to the evaluation such as would include the child’s primary care physician who has treated the minor child QXV since birth . Mountville Family Practice Treatment Notes for the Minor Child QXV), the child’s teachers, principals, school counselors’ etc. 210. In fact the PLAINTIFF/ Father has subsequently spoken to all the aforementioned who have stated categorically that they have seen no indication whatsoever that the child should require evaluation for psychological or psychiatric concerns or medication. 211. DEFENDANT WF lied to the Doctors she asked to treat her son the minor child QXV making up detailed symptoms which make clear her interest in gaining drugs/medication for the child’s falsely reported symptoms. 212. Though the psychiatrist’s (DEFENDANT DR OO) own report of his personal evaluation of the child demonstrated that there was no problem with the minor child QXV, DEFENDANT DR OO did allow himself to be manipulated by DEFENDANTS KY & WF and did prescribe drugs completely against the code of medical ethics, the wishes, practices and beliefs of the PLAINTIFF/Father and the best interests of the minor child QXV. 213. DEFENDANTS manipulated the child into an incorrect diagnosis and drugs that have killed numerous children and that have significant side effects and long term dangers. (SEE EXHIBIT V. and W., Articles on Adderal and Remeron prescribed by DEFENDANT OO to the minor child QXV). 214. DEFENDANT willfully withheld information of the psychiatrist’s treatment of the minor child QXV from the child’s primary care physician since birth (SEE EXHIBIT U.), the child’s teachers, principals, school counselors’ etc. 215. The minor child QXV’S PLAINTIFF/Father has subsequently spoken with all of the aforementioned professionals in his child’s life who have stated categorically that they have been given no information whatsoever regarding the fact that the child had been evaluated and diagnosed by psychologists and/or psychiatrists, nor that the child had been on psychotropic drugs. 216. This particular omission and fraud on the part of DEFENDANT WF is particularly heinous in that DEFENDANT WF is well aware that these teachers, counselors and doctors should know about any medication the child may have previously been prescribed as they are tasked with treating and working the child and his health. 217. This specific act of omission committed by the DEFENDANT WF in the interests of providing her a better advantage in custody court is particularly heinous and negligent toward her own child, as it opened the child to the potential of a horrible state of circumstances which could have resulted in the child’s injury or death or at a minimum misunderstanding of the child’s behavior, as a result of the child’s primary care physician and other professionals who are asked to care for the child for hours at a time at school, having no idea the child had previously been prescribed these powerful drugs. 218. DEFENDANT WF did willfully cause further danger and showed absolute disregard for the child’s safety and best interests by giving the child psychotropic drugs for days consecutively and then allowing the child to go through repeated potentially deadly withdrawal each and every time the minor child QXV went to his fathers for a visit. (SEE EXHIBIT V. and W.). 219. The DEFENDANT WF’S unconscionable actions in allowing the child to endure withdrawal from these powerful drugs specifically during visits with the child’s PLAINTIFF father did result in stressful and dangerous visits with the PLAINTIFF/father as the PLAINTIFF/father had no idea why the child was acting strangely and could have been put in a deadly position by the DEFENDANT WF’S deliberate withholding of this critical information about the child’s health and well being. 220. DEFENDANT WF did refuse to inform the PLAINTIFF/father that the child had been evaluated, diagnosed and medicated. 221. PLAINTIFF did later discover these facts through his own investigation, many months after the fact. 222. This DEFENDANT WF’S refusal to share critical information concerning the child’s health and welfare with the child’s father who has shared custody of the child is not only an egregious violation of the child’s basic rights to safety but is also in direct opposition to the orders of the court (SEE EXHIBIT A.). 223. The DEFENDANT WF has previously been diagnosed with and/or admitted to having problems in her life with the following: Severe Traumatic Brain Injury, Passive Aggressive Syndrome Disorder, Narcissism, Mixed Disturbance of Emotions and Conduct, Extreme Sleep Deprivation, and according to her accusations is a survivor of the following traumas, ACOA (adult child of alcoholics), Child Sexual Abuse, Rape & Incest, Child Physical Abuse. 224. The medical director at Philhaven has subsequently admitted that the evaluation and diagnosis are based upon input from the DEFENDANT only and that the child should not have been medicated without PLAINTIFFS approval. (SEE EXHIBIT X., Letter to PLAINTIFF from Dr. Sparrow, Medical Director, Philhaven). 225. Upon PLAINTIFF bringing the facts to their attention; All facilities and offices operated by Philhaven immediately modified their policies as a directive from the CEO and the legal department based upon their recognition of what the DEFENDANT had done by manipulating their operations and services. 226. The DEFENDANTS have demonstrated that they are incapable or unwilling to make decisions in the best interest of the child and are fully and negligently willing to risk the child’s life to gain advantage in the acrimonious custody battle which they are relentlessly waging against the third father PLAINTIFF of DEFENDANT WF’S third child, the minor child QXV. 227. PLAINTIFF has seen no symptoms or behavioral problems reported to be happening at the DEFENDANTS home/Church/etc and while under DEFENDANTS’ custody. Thus it is likely the symptoms are imagined, strategically created or caused by the DEFENDANTS’ issues, problems and manipulations/abuses. 228. DEFENDANTS did exhibit extreme negligence by manipulating the child’s primary care physician for the purposes of interfering with visitation and the PLAINTIFFS rights (SEE EXHIBIT AA. Mountville Family Practice Letter to PLAINTIFF) against the spirit and letter of the law and the custody order in place governing the care and custody of the minor child QXV. 229. DEFENDANT WF did breach the trust of The child’s doctors and their ability to believe reports of symptoms as being honest as referred to herein and in EXHIBIT Y., Dr. Parke’s Letter To DEFENDANT WF and other supporting letters/prescription notes from Mountville Family Practice to such a degree that the physicians who have treated the minor QXV all his life will no longer see him and the family was discharged from care by the physicians (SEE EXHIBITS V., Y. and AA. Mountville Family Practice Letters and Notes). 230. That the actions of DEFENDANT WF which caused the physicians who have treated the minor QXV all his life to no longer see him and the same actions which caused the physicians to discharged the family from care by the physicians where taken for the sole purpose of furthering the conspiracy detailed herein to deny the PLAINTIFF father his rights and to circumvent the Custody Order (SEE EXHIBITS V., Y. and Z. Mountville Family Practice Letters and Notes and SEE EXHIBIT A Custody Order). 231. DEFENDANTS failed to notify PLAINTIFF that the doctors would no longer treat the child so that father would have mistakenly taken child to said practice in the case of an emergency but then would have found out that the doctors had notified DEFENDANT WF a month in advance that said medical treatment was being discontinued due to DEFENDANT WF’S “inappropriate actions.” (SEE EXHIBITS V., Y. and Z. Mountville Family Practice Letters and Notes and SEE EXHIBIT A Custody Order). 232. The DEFENDANT Calvary Church has refused to respond to constant, group, individual and separate pleas to stop the damage being done to the child and PLAINTIFF throughout the past three years including but not limited to the providing of facts and evidence by the PLAINTIFF and numerous members, member families and more recently Elders. 233. DEFENDANT CC has had every opportunity and all information required to fully understand the actions being carried out under the guise of “Ministry” and the damage and destruction DEFENDANTS are effecting on PLAINTIFF and QXV but DEFENDANT CC refuses to accept, address or stop said actions thus supporting and building the abuse and assault under the claim of “doing God’s work”. 234. DEFENDANT CC has taken on full culpability and has been clearly and unarguably negligent in actively participating in causing, fostering and promoting the herein-mentioned actions and associated damages. 235. DEFENDANT CC has consistently refused to provide information, records or evidence requested by PLAINTIFF 236. DEFENDANT CC has maintained from the top (Pastor Johnny Miller) down the line that they are “doing God’s work” by carrying out this campaign against the PLAINTIFF as a course of their Ministry. 237. The DEFENDANT Calvary Church has been additionally negligent in that the DEFENDANT CC has avoided, neglected or overridden its own rules of governance and ethics thus allowing the continuation of said campaign against PLAINTIFF without allowing the built in safeguards to prevent, negate or relieve the damages caused by DEFENDANTS actions as these rules were designed to do. 238. In specific DEFENDANT CC has allowed members to hold DEFENDANT CC official positions while suffering what they refer to as “brokenness” – this in direct opposition to their Church bylaws which are in place to prevent this type of situation. 239. DEFENDANT Calvary Church Pastor Johnny Miller has effected the individual domination and rule of said organization by bypassing the intended rule by Elders. 240. Thus DEFENDANT CC breached the implied covenant of good faith by rendering the Elder Board review process a sham. 241. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 242. That said actions are willful, wanton and deliberate and constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. COUNT VI. Obstruction of Justice 243. Paragraphs 1 through 242 are incorporated by reference as though set forth in full herein. 244. That the DEFENDANTS did willfully and with malicious intent obstruct justice and the process of justice by conspiring to lie to, misinform and manipulate Police Departments, the Lancaster County District Attorneys Office, the Offices of District Justices, Physicians, Psychiatrists, School officials and others in their campaign to keep PLAINTIFF from gaining justice in the court system 245. As example PLAINTIFF cites the following: 246. That subsequent to and built upon false criminal charges filed on December 22, 2003 (SEE EXHIBIT O. - Harassment # 2) the DEFENDANTS WF, KY and George May did create and effect a plan to keep the Lancaster County District Attorney’s Office from allowing a legitimate change of conditions of bail by lying to the Assistant District Attorney, David Dye about specific facts and details. 247. That DEFENDANTS WF, KY and George May did conspire to and did contact Chief Fiorel, the Chief of Southern Regional Police Department and trick him into making statements which did not accurately represent his overall opinion but rather which questions were designed to allow the manipulation of Chief Fiorel’s words to trick Assistant District Attorney, David Dye into making incorrect statements/claims to Judge Stengle and blocking PLAINTIFFS request to follow the court order of Judge Hummer (SEE EXHIBIT A and O.). 248. That DEFENDANTS WF, KY & GM did then conspire to and contact Assistant District Attorney, David Dye and convince him to take a position against PLAINTIFF and his attempts to see his son QXV based upon the manipulation, deceit and subterfuge of DEFENDANTS WF, KY & GM in representation and authority of DEFENDANT CC. (SEE EXHIBIT A and O.) 249. That DEFENDANTS have refused to provide records, documents and details to PLAINTIFF as is his right to obtain same and that DEFENDANTS have done so with the intent to keep said evidence from being utilized in custody, criminal and civil proceedings and to prove PLAINTIFF’S innocence and/or PLAINTIFFS truthful position as the best parent to raise the child QXV due to the actions and danger created by DEFENDANTS individually and as a group. 250. As example that DEFENDANT CC has claimed that there are virtually zero records (SEE EXHIBIT J.) although DEFENDANT KY admits in her email (SEE EXHIBIT D.) that she has been counseling the child and possibly for years and even though DEFENDANT KY claims to have sufficient counseling time and experience with child to refer him for psychiatric help and drugging none of which is in synch with the realities of professional counseling norms, the ACA Code of Ethics regarding the taking of notes and keeping of records nor the DEFENDANTS own story. 251. That DEFENDANT KY did refuse to appear under subpoena and has resigned her position at CC instead of answering any legitimate questions and revealing what damage has been done to QXV by her and the other co-conspirators. 252. That the DEFENDANT WF has tried on numerous occasions to have her own son labeled, misdiagnosed and drugged in an attempt to contravene the orders of the court in the custody of the minor child QXV and in direct opposition to all of her statements about how troubled her child is she signed a report along with numerous professionals and the child’s father stating that the child is just fine and in fact doing very well in direct opposition to the statements of WF to the psychiatrists and counselors she lied to (SEE EXHIBIT AA., CV Exceptional Student Evaluation). 253. That said actions constitute violations of law and ethics of such an egregious and determined nature as to call for Actual damages in the amount to be determined at time of trial but not less than $700,000. 254. That said actions constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to deter others from carrying out such actions and behavior in the future. 255. WHEREFORE, PLAINTIFFS pray for: 256. A preliminary and permanent injunction against all DEFENDANTS, their agents, servants, employees, employers, attorneys, affiliates, heirs and assigns, and any other individual or entity within their control or supervision and all other persons or entities acting in concert with him or on his behalf or participating with him, as follows: 257. directing all DEFENDANTS to immediately cease, stop, desist from and to discontinue any and all activities listed herein as offences and or otherwise interfering with the life, well being and relationships of Bennett J. Vonderheide and his minor son Quinta; 258. enjoining all DEFENDANTS from aiding, abetting, encouraging or endorsing any other party, including present or former agents, employees and/or members of Calvary Church to do any of the aforementioned acts; 259. granting PLAINTIFF Vonderheide such further relief as this Honorable Court may deem necessary or appropriate. 260. Compensatory damages in the form of lost profits and business losses occurring over the past three years and for the foreseeable future $700,000. 261. Pain and suffering in the amount to be determined by the court on a by count basis and in consideration of the fact that said actions constitute violations of law and ethics of such an egregious nature as to call for Punitive Damages in the amount to be determined by the court so as to seriously deter others from carrying out such actions and behavior in the future. 262. granting declaratory judgment that the DEFENDANTS must pay the PLAINTIFF for actual damages and punitive damages for pain and suffering as is determined by the court; 263. Further exemplary and punitive damages for DEFENDANTS’ willful and intentional tortuous conduct as the court deems appropriate. 264. Other relief as this Honorable Court deems just. 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
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What do you do when a church does wrong and won't make it right? After going to Calvary leadership time and time again, this website takes the sins of the church to the rest of the body of Christ in the hopes that Calvary repents and does the right thing! Matthew 18:15-17 "If your brother sins against you, go and show him his fault, just between the two of you. If he listens to you, you have won your brother over. But if he will not listen, take one or two others along, so that 'every matter may be established by the testimony of two or three witnesses.'If he refuses to listen to them, tell it to the church; and if he refuses to listen even to the church, treat him as you would a pagan or a tax collector." |
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