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Wendy Flanders Identifying Data

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BRIEF IN SUPPORT OF PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY AND VISITATION ORDER

IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL ACTION - CUSTODY

BENNETT J. VONDERHEIDE	:
	:
VS.	:	No. CI - 02 - 05945
	:
WENDY LOUISE FLANDERS	:

BRIEF IN SUPPORT OF PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY AND VISITATION ORDER

AND NOW, this 25th day of May 2004, in support of the aforementioned, I, Bennett J. Vonderheide, do submit the following:

Ms. Wendy Flanders has carried out a willfully deceitful campaign in complete contempt of the “ORDER” for custody dated the 13th of September 2002 No. CI-02-05945 (Exhibit A) signed by Wayne G. Hummer, Jr., Judge. In her contemptuous activity Ms. Flanders has ignored the order of this court setout in part here as Follows;

CLAIMS

I. Specific Citations of Contemptuous Activity

ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A: reads in part:

“Legal custody of Quinta Xzavier Vonderheide, the child of the Parties, shall be shared by the parents. Each parent shall have the right to participate in the major decisions affecting the child, including but not limited to, medical, religious and educational decisions and each parent shall have equal access to medical, dental and school records, the residence address of the child and of the other parent”

A. Ms. Flanders unilaterally changed the child’s name with the primary intent to cause physical, psychological and emotional separation from the natural father and to further her goals of alienation of affection and elimination of the natural father from all elements of the child’s life. SEE DOCUMENTS ATTACHED (ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A, EXHIBIT B THE NAME GAME)

B. Ms. Flanders having primary physical custody of the child has failed to provide to the father, advance information on a timely basis regarding school programs, events, meetings and teacher conferences.

C. Ms. Flanders played a game of taunting for months before child entered kindergarten refusing to advise the father of where or even if the child would be going to school and by what name he would be attending.

D. Ms. Flanders eliminated the father from two preschools and any activities by changing the child’s name numerous times. (See EXHIBIT B THE NAME GAME).

E. ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A reads in part; “When Mother begins school Father shall have partial physical custody one night each week, which shall either be a Tuesday or Wednesday depending upon the child's school schedule, from 4:00 p.m. on such day until 4:00 p.m. on the following day.”

1. Ms. Flanders refused to allow the child to spend the court ordered time with the father during school, initially restricting the visits to 4:30 PM – 6:30 PM only.

2. Ms. Flanders has refused to make the child available for these visits at all over the past five months (see above).

F. ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A reads in part; “The parents shall meet at the Conestoga Wagon Restaurant to exchange custody.”

1. Ms. Flanders refused to follow the court order for exchanges insisting instead that father submit himself to entrapping, specific, domineering and confrontational conditions or Ms. Flanders refused to make the child available.

2. Combined with condition of bail Ms. Flanders used this method to keep the child from having any visits over the past five months. Including Christmas, Easter and all. (Child’s presents opened 5/15/04).

3. Specifically Ms. Flanders refused to bring the child to the Wagon restaurant as specified in the court order.

4. Ms. Flanders stated to the counselors at her church that an attorney had advised her to make these changes on her own.

5. Ms. Flanders told the child throughout the five-month 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.’

6. Furthermore Ms. Flanders had the child dress up and wait falsely for the father after refusing to allow visitation (including Christmas Eve).

7. The child would then cry and Ms. Flanders expressed what a bad guy the father is for not visiting the child.

8. On May 13th 2004 Mr. James Wolman (Exhibit C) finally came out from the shadows and admitted he was representing Ms. Flanders in this case.

9. The father immediately demanded that Mr. Wolman instrument the Court’s Order and explain such Order to is client.

10. Mr. Wolman refused on first call and stated he had to go.

11. The next morning Mr. Wolman called back and had reconsidered.

12. The first visit in five months took place on May 14th 2004 (the next day).

G. ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A reads in part “Both parents shall permit reasonable telephone access to the child while the child is in his or her custody.”

1. Ms. Flanders has consistently kept the child from telephone contact at every opportunity as one example I submit the following two instances;

a. June 15th 2003 through June 22nd 2003 the father had the child on family reunion. As always the father made the child call Ms. Flanders every day.

b. From June 23 2003 through July 14th 2003 Ms. Flanders took her “equal time" and completely refused to allow the child to call his father at all.

c. From September 15th through September 29th 2003 the father called twenty three times leaving a message for the child to return his call.

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

e. The child did not call at all but Ms. Flanders used the records of these calls to file criminal harassment charges (charges dismissed when District Attorney heard tapes).

f. During this false charge the child was kept from telephone contact for the period from September 14th 2003, through May 14, 2004 except for five calls which were in fact well directed, listened in on and word by word coached by Ms. Flanders.

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

i. Petitioner has made numerous phone contacts with attorney
Wolman over the past weeks requesting that Attorney Wolman
instrument the order of Judge Hummer and 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

iv. Until Saturday 5/22/04 when petitioner realized the futility of
the exercise.

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

vi. And furthermore the child has stated that he has not received
the messages left for him on Ms. Flanders answering machine

i. For the record I have witnessed Ms. Flanders listened in and prompted Bryna AKA Elizabeth, etc on every call her father ever made to her in my presence.

H. ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A reads in part; “The parents are encouraged to accommodate the reasonable requests of the other parent for alterations of any agreed upon Schedule, as the circumstances and best interests of the child require.”

1. Father agreed to allow the child to return early from his vacation time at Ms. Flanders request. (June 14th above reunion)

2. Ms. Flanders stated in writing that she would allow make up of this week’s time but refused.

3. Ms. Flanders has never once given any additional time or accommodated the father to modify a visit.

4. Ms. Flanders is not capable of accommodating normal adjustments but rather uses these opportunities to hurt father by playing him to the end pretending to “work things out” and inevitably refusing the visit to occur in the “child’s best interest”.

5. The father has made deals with Ms. Flanders and requested the child be permitted to visit his grandparents, aunts, uncles, cousins, friends, etc when they are in town or having an event but Ms. Flanders has broken her word and otherwise kept the child from these opportunities each time.

6. Ms. Flanders kept the child from his own birthday party at the river when all his relatives came in town June 25th 2003.

I. ORDER OF WAYNE G. HUMMER, JR., JUDGE EXHIBIT A reads in part; “Both parents shall encourage the child to love and respect the other parent and shall not state, nor allow others to state, in the presence of the child, derogatory comments about the other parent. Both parents shall encourage the child to have significant contacts with the other parent, and. shall make certain that the child is ready on time for the transfer of physical custody from one parent to the other.”

1. As with all of her contemptuous activities Ms. Flanders has broken this item in so many ways I cannot detail. Therefore I focus on the following demonstrable examples:

A. Ms. Flanders has poisoned the child with derogatory impressions about his father for over two years now and at every point.

B. First and foremost Ms. Flanders has consistently found new people and played the abused mother act soliciting their well-intentioned protection from the child’s “Bad Daddy”.

C. Ms. Flanders has used the false accusations and legal filings (see above) to support and convince these individuals and organizations that the child’s father is a terrible man and should be feared.

D. Ms. Flanders has used the false accusations and legal filings to support and convince these individuals and organizations that the father has no concern about the child but only wants to hurt Ms. Flanders.

E. One organization at point is the Calvary church and Ms. Kathy Yoder as their agent.

F. Ms. Flanders has brainwashed the child into thinking his father is completely at fault and Ms. Flanders is just a poor victim.

G. As example I submit the notes and quotes the most recent visit this week. SEE EXHIBIT C Quinta Quotes 5/15/04 (first time alone and visitation after five months of programming).

2. Further, Ms. Flanders abused the process of law by falsely swearing, falsely
testifying and filing false accusations causing alarm with all the child’s “new
contacts” and again interfering with Child/Father relationship. These
accusations include;

A. Two Protection From Abuse Orders (PFA/PFA’s),

B. Five PFA violations attempts

C. Two criminal harassment charges. On one charge alone Ms. Flanders has so manipulated custody that the child has not had a visit with his father for five months.

D. In each occasion the filing was used to keep the child away from his father as long as possible. During these periods Ms. Flanders allowed the child no phone contact with his father.

1. NOTE: By way of demonstrating the long-term pattern of Ms. Flanders I have a large body of evidence to submit in the case of Mr. John Harris No. CI-99-4401 transpiring the past nine years in Lancaster courts with a near identical pattern.
2. There is a third case with the first father of Ms. Flanders three children, which will further demonstrate history and pattern.

3. In all these three cases with three children and three fathers have identical behavior by Ms. Flanders over a period of years.

4. Interviewing or testimony of the two older children will show the results of these patterns on the childhood development.

III. Conclusions

A. This child is blatantly, maliciously and deceitfully programmed in each and every thought of his father and requires extensive time with his father to heal this brainwashing.

B. Furthermore the Mother requires extensive and intensive control mechanisms and treatment to stop this poison!

IV. Request for Relief

Therefore I request the Court;

A. Place the child into the immediate care and grant full custody to his father and take such measures as the Court sees fit to stop this behavior and the psychological emotional and mental hardship on the child.

B. Furthermore that the Court eliminate any and all unsupervised contact between the child and Ms. Flanders pending professional evaluation of the effect of Ms. Flanders condition and actions upon the child and the safety of the children’s and Ms. Flanders lives.

Respectfully;

___________________________________

Bennett J. Vonderheide
Pro se

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