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Quinta Xavier Vonderheide

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Wendy Flanders' Accusations Against;

Mr Vonderheide

Mr Harris

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Quinta Xavier Vonderheide

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Current Custody Order

Birth Certificate

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Mr Vonderheide

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Filings by; Mr Vonderheide

1. Petitioner is Bennett J. Vonderheide, Plaintiff in the above captioned case.

2. Respondent is Wendy L. Flanders, Defendant in the above captioned case.

3. The parties are the parents of a minor child, namely Quinta Xzavier Vonderheide, born 6/24/98, age 5.

4. Subsequent to a custody conference dated August 23, 2002 custody order was signed by Judge Wayne G. Hummer, Jr. on September 13, 2002.

1. Respondent refused to allow the child to spend the court ordered time with the father during school year (including holidays), restricting the visits to 4:30 PM – 6:30 PM only.

2. Respondent completely eliminated these visits from December 20, 2003 through May 18, 2004 (the past five and a half months).

3. On 5/17/04 Petitioner contacted Mr. Wolman to request that he instrument the order for the child’s weekday visit.

a. On 5/18/04 Mr. Wolman left a message that Respondent had advised that she and Petitioner had agreed to 4:30 p.m. - 6:30p.m.

b. Petitioner recited the Order of the Court to Mr. Wolman.

c. In an effort to see the child and not cause confusion Petitioner stated that Petitioner would accept what Mr. Wolman could get her to comply with at this time.

d. Petitioner stated that anything less than what the order calls for is in contempt and again demonstrates Respondent refusal to follow the Orders of the Court.

e. Daphne, Mr. Wolman’s secretary called and told the Petitioner that Respondent was willing to allow the visit to go until 7:30 but Petitioner needed to feed him in order to get this ‘privilege.’

f. Respondent went to Petitioners property early, (at 7:00 p.m. not 7:30 p.m.) and took the child.

g. Respondent refused to produce the child for the following Tuesday, visit, May 25, 2004. Mr. Wolman refused to respond.

1. Respondent refused to follow the Court Order for the exchanges, insisting instead that the Petitioner go to different locations and be subject to confrontational conditions, or Respondent refused to make the child available.

2. Respondent told the child throughout the five months of contempt that “the judge told daddy to come up into her driveway,” and, that his, “daddy deserved to get arrested for not following the judge’s orders.”

1. Respondent has consistently kept the child from telephone contact at every opportunity;

a. June 15, 2003 through June 22, 2003 Petitioner took the child to his family’s reunion. The Petitioner made sure the child called Respondent every day.

b. June 23, 2003 through July 14, 2003 Respondent took her “equal time" and did not allow the child to call Petitioner, at all.

c. September 15, through September 29, 2003, the Petitioner called twenty three times leaving a message for the child to return his calls.

d. This was with the help, advice and direction of the local police department, church counselors and Respondent psychologist.

e. The child did not call at all but, Respondent used records of these calls to file criminal harassment charges.

i. The charges were dismissed for lack of evidence, (May 13, 2004) Judge Stengle.

f. Prior to dismissal of this false charge the child was kept from telephone contact with Petitioner for the period from September 14, 2003, through May 14, 2004 except for five calls which were in fact well directed, listened in on and word by word coached by Respondent.

g. Although the Petitioner has appeared in front of this court six times in the past eight weeks, bringing attention to the contemptuous activities of Respondent, while alerting Respondent and her attorney of this item of contempt Respondent continues to refuse to allow Petitioner telephone contact with his son.

i. Petitioner has made numerous phone contacts with attorney Wolman requesting that Attorney Wolman advise his client to comply with the order of Judge Hummer and to advise his client to comply in all ways including telephone contact in the best interests of the child.

ii. Attorney Wolman encouraged Petitioner to call.

iii. Petitioner called on a daily basis.

v. Throughout this process there has been zero phone contact with the child.

vi. The child has stated that he has not received the messages left for him on Respondent’s answering machine.

vii. Over the past two years Respondent has effectively eliminated the normal phone contact between the Petitioner and the child which contact is clearly specified in the Order of Judge Wayne Hummer, Jr.