Tolu v. Reid Et Al

Electronically Filed - St Louis County - September 10, 2020 - 12:11 AM
20SL-CC04680
IN THE TWENTY-FIRST JUDICIAL CIRCUIT COURT

SAINT LOUIS COUNTY, MISSOURI
EVITA TOLU )
)
Plaintiff )
)
v. ) Cause No.
)
JAMES D. REID, PH.D., individually ) Division No.
Serve: 6366 Wydown Boulevard ) JURY TRIAL DEMAND
Clayton, MO 63105 )
and )
)
JAMES D. REID, PH.D., LLC, a Missouri limited )
liability company, )
Serve: James D. Reid, Registered Agent )
7 North Jackson Avenue, Suite 100 )
Clayton, MO 63105 )
and )
)
ELAINE PUDLOWSKI, ESQ., individually, )
Serve: Elaine Pudlowski, Esq. )
231 S. Bemiston Avenue, Suite 1111 )
Clayton, MO 63105 )
and )
)
JENNIFER WEBBE VAN LUVEN, LCSW, individually, )
Serve: Jennifer Webbe Van Luven, LCSW )
West County Psychological Associates )
12125 Woodcrest Executive Dr. Suite 110 )
Creve Coeur, MO 63141 )
and )
)
FITZGIBBONS PSYCHOLOGICAL ASSOCIATES )
a/k/a WEST COUNTY PSYCHOLOGICAL ASSOCIATES)
Serve: Mary Fitzgibbons, President )
West County Psychological Associates )
12125 Woodcrest Executive Dr. Suite 110 )
Creve Coeur, MO 63141 )
)
)
)
Defendants. )
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TABLE OF CONTENTS
PETITION & DEMAND FOR TRIAL BY JURY
Pages
PARTIES JURISDICTION & VENUE 2-4
COMMON FACTS & ALLEGATIONS 4 - 44
A. Plaintiff’s Family History That Led to Plaintiff’s Divorce 4 - 14
B. Family History That Led to Plaintiff’s Seeking Modification of Child
Custody 14 - 19
C. Facts Related to Breach of the Standard of Care and Breach of Contract

by Defendant Reid 19 - 32
D. Facts Related to the Breach of Fiduciary Duty by Defendant Pudlowski 32 - 36
E. Facts Related to the Breach of the Standard of Care & Fiduciary Duty by
Defendant Van Luven 36 - 44
COUNT I Breach of Standard of Care Defendants Reid & Reid LLC 45 - 49

COUNT II Breach of Contract by Defendants Reid and Reid LLC 49 - 51
COUNT III Breach of Fiduciary Duty by Defendant Pudlowski 51 - 54
COUNT IV Breach of Standard of Care by Defendants Van Luven and Fitzgibbons 54 - 57
COUNT V Breach of Fiduciary Duty by Defendant Van Luven and Fitzgibbons 58 - 61
COUNT VI Violations of the Merchandizing Practices Act by Defendants Reid,
Pudlowski and Van Luven 61 - 63
EXHIBIT 1 Court Order Appointing Pudlowski

EXHIBIT 2 Statement of Understanding between Plaintiff & Defendant Reid
EXHIBIT 3 Informed Assent between Plaintiff & Defendant Reid
EXHIBIT 4 Court Order limiting release of the Reid Report
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PETITION AND DEMAND FOR TRIAL BY JURY
COMES NOW, Plaintiff, Evita Tolu (“Plaintiff”) and for her Petition against Defendants
James D. Reid, Ph.D., James D. Reid, Ph.D., LLC (collectively “Reid”), Elaine Pudlowski
(“Pudlowski”), Jennifer Webbe Van Luven and Fitzgibbons Psychological Associates, also known
as, West County Psychological Associates (collectively “Van Luven”), who provided services to
Plaintiff, states as follows:
PARTIES, JURISDICTION AND VENUE
1. Plaintiff is an individual who resides in Saint Louis County, Missouri.
2. Defendant Reid is a Missouri licensed psychologist, with his principal place of
business in Clayton, Saint Louis County, Missouri.
3. Defendant James D. Reid Ph.D., LLC is a Missouri limited liability company with
the principal place of business in Clayton, Saint Louis County, Missouri. At all relevant times
hereto, Reid acted within the scope and course of his employment, servancy and/or agency for
James D. Reid, Ph.D., LLC.
4. On his website Reid holds himself out to the public and to Saint Louis County
Courts as a licensed psychologist with over twenty (20) years of clinical and forensic psychology
experience as an expert witness primarily for individual and family assessments in family-law
proceedings, including divorce, child custody and child custody modifications.
5. On October 26, 2017, the Court appointed Reid as an expert in Plaintiff’s custody
modification case, Tolu v. Stientjes, Saint Louis County Circuit Court, Case No. 16SL-DR04088-
01, to “evaluate the psychological status of Petitioner and Respondent, and their two minor
children, and to assess any allegations or issues regarding their current mental health and the
parenting ability of each parent specific to this case bearing on the best interests of their two minor
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children. The Evaluator shall offer opinions and recommendations regarding this case” and to
“exercise his independent objective judgment in conducting the evaluation.”
6. Defendant Pudlowski is an attorney licensed to practice law in Missouri, with her
principal place of business in Clayton, Saint Louis County, Missouri.
7. Pudlowski is a certified, court appointed guardian ad litem (“GAL”), domestic law
mediator and parent coordinator. Pudlowski was a Court appointed GAL on August 30, 2017, in
Plaintiff’s custody modification case, Tolu v. Stientjes, Saint Louis County Circuit Court, Case
No. 16SL-DR04088-01.
8. Defendant Van Luven is a Missouri Licensed Clinical Social Worker (“LCSW”),
with her principal place of business in Creve Coeur, Saint Louis County, Missouri.
9. Defendant Fitzgibbons Psychological Associates is a professional entity conducting
business under the fictitious name of West County Psychological Associates (sometimes referred
to as “Fitzgibbons”), with its principal place of business in Creve Coeur, Saint Louis County,
Missouri. At all relevant times hereto, Van Luven acted within the scope and course of her
employment, servancy and/or agency for Fitzgibbons.
10. Van Luven, on her website, holds herself out to the public, as a Missouri LCSW
experienced “in therapy with high conflict relationships and divorce counseling,” in working “with
children and adolescents experiencing difficulties related to divorce or reunification.” Van Luven
also offers services as a Parent Coordinator, Co-Parent Counselor, Custody Evaluator and Divorce
Consultant.
11. Van Luven works for and serves as an Associate Director for Fitzgibbons.
12. On September 17, 2018, in Plaintiff’s custody modification case, Tolu v. Stientjes,
Saint Louis County Circuit Court, Case No. 16SL-DR04088-01, the Court appointed Van Luven as
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therapist to reunite the parent’s minor children and “to focus on re-establishing the relationship
between the parent’s minor children,” and “to re-establish the relationship between the minor
children and the parents,” and “to reunify the family and improve relationships within the family.”
13. The incidents that gave rise to this cause of action took place in Saint Louis County
and, therefore, venue is proper in Saint Louis County, Missouri.
COMMON FACTS AND ALLEGATIONS
A. Plaintiff’s Family History That Led to Plaintiff’s Divorce
14. Plaintiff is a first-generation immigrant from Russia, who came to the United States
at the age of twenty-five (25) in 1993. Plaintiff obtained a combined Bachelor and Master’s,
Degrees in Arts majoring in teaching English as a second language from the University of Tula, in
the former Soviet Union.
15. On April 3, 2002, Plaintiff married Robert Stientjes (“Stientjes”).
16. While married, Plaintiff and Stientjes had two children, Child A born in 2002 and
Child T born in 2004. (The names of the children are withheld to protect their privacy).
17. Child A was diagnosed with an autistic spectrum disorder at the age of three (3)
after Plaintiff observed that Child A, walked on his toes, developed an eating disorder that required
intensive treatment and hospitalization, got upset for no reason, had inexplicable facial
expressions, was aggressive, avoided eye and physical contact, and had difficulty sleeping. At the
age of seven (7), Child A was also diagnosed with Attention Deficit and Hypoactivity Disorder
(ADHD) after Child’s A elementary school teacher reported that Child A was aggressive and
disruptive in class and interfered with the teaching process.
18. Plaintiff’s family struggled through cycles of abuse during the marriage. The verbal
abuse started early in the marriage, before and after their children were born, with Stientjes often
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calling Plaintiff “a Russian whore,” “my slave,” “a worthless bitch,” “my chattel,” “a Russian
slut,” “a stupid Russian,” “a Commi,” and “a bad and worthless mother.” Often, Stientjes
disparaging epitaphs toward Plaintiff were expressed by shouting at the top of his lungs in the
presence of Child A and Child T.
19. Stientjes abused Child A and Child T, physically and emotionally during his cycles
of abuse. Daily, Stientjes referred to Child A and Child T as “stupid,” “crazy,” “turd,” “complete
failure,” “queer,” “faggot,” “little shit,” “loser,” “hypochondriac,” and “wussy,” whether Plaintiff
was present or not.
20. The first phase of the abuse cycle is the “honeymoon phase,” where the abuser
creates a safe place filled with love and a sense of security in the relationship. The victim is drawn
close to the abuser, by a powerful sense of belonging. The victim is enticed by the abuser’s ability
to say and do the right things at the right time.
21. The second phase of the abuse cycle is the “tension building phase”, which begins
when the victim becomes aware of tension increasing in the relationship. The abuser uses a variety
of techniques to maintain control over the victim, such as the silent treatment, jealousy, mind
games, blaming, and gaslighting. The victim tries to appease the abuser in order to decrease the
tension.
22. The third phase of the abuse cycle is when the abuse is exposed or the abuser feels a
loss of control, the “explosive phase”, begins where the victim becomes the target of verbal,
emotional, physical and sexual abuse at the whim of the abuser. Then, the abuser knows just what
to say and/or do to begin the endless cycle of abuse all over again.
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23. Plaintiff was naïve to the fact that she was a victim of domestic and intimate partner
violence as she dutifully and lovingly met Child A’s and Child T’s needs for emotional support,
loving parenting, and access to appropriate medical and mental health treatment.
24. Plaintiff continued to focus Child A and Child T, on positive behaviors by
motivating them to engage in sports and art, engage them with their emotions, to accept
responsibilities at home, improve their social skills, and to be respectful towards their parents.
Plaintiff continually attempted to provide support to Child A and Child T to decrease the impact of
Stientjes’ explosive anger cycles. However, Plaintiff was not able to protect Child A and Child T
or herself from Stientjes’ never ending abuse and failed to end her marriage in the early stages of
the abuse cycle.
25. On November 23, 2005, Stientjes’ hostile and aggressive behavior extended beyond
the Plaintiff’s home. Stientjes, who is a tax attorney practicing before the Internal Revenue
Service (“IRS”), left “a scathing voice message containing profanity and otherwise abusive
language,” for an IRS attorney. The IRS considered the voice message to be in violation of
Circular No. 230 and posed a threat to the IRS employee whom Stientjes unjustifiably attacked.
The Director of Professional Responsibility for the IRS initiated disciplinary proceedings against
Stientjes seeking his “suspension from practice before the IRS.”
26. In order to avoid suspension, Stientjes lied to the IRS that Stientjes “immediately
sought help and received therapy for stress and anger management to modify his behavior” “from a
licensed therapist to assist [him] with stress and anger management issues.” Stientjes also lied to
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the IRS that the “defense of ‘listed transactions 1,’ is an area of tax law, which I no longer pursue in
my practice.”
27. In fact, Stientjes never sought any help for his anger management. Stientjes
continued to represent taxpayers involved in IRS prohibited transactions even after he lied to the
IRS during his disciplinary proceedings and through July 2016. In reliance on Stientjes’ lies, on
March 27, 2008, the IRS placed Stientjes on a three (3) year probation in lieu of or to replace his
suspension.
28. In 2011, during one of the “honeymoon phases” of Stientjes’ abuse cycles, Stientjes
told Plaintiff that he wanted to adopt an older female minor child from a foreign country. Feeling
safe at that time and wanting to preserve the peace in the family for the sake of Child A and Child
T, neither Stientjes nor Plaintiff reported the never-ending domestic violence to the adoption
agency during its home study in 2012. The adoption stopped when war erupted in the adoptive
foreign country in 2013. At that time, Stientjes had transitioned to the “explosive phase” of his
abusive cycle.
29. Although Stientjes somewhat curbed his anger professionally, it was anything but
behind closed doors in the family home. Over time, Child A and Child T where emulating similar
behavior to Stientjes in showing disrespect and aggressiveness toward Plaintiff at the
encouragement of Stientjes. Stientjes realized that he was slowly losing control over Plaintiff and
on May 14, 2015, Stientjes requisitioned Child A to “teach mom a lesson” with a baseball bat,
forcing Plaintiff to flee from the family home out of fear for her life.
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A transaction that is the same as or substantially similar to one of the types of transactions that the IRS has
determined to be a tax avoidance transaction and identified by notice, regulation, or other form of published guidance
as a listed or prohibited transaction.
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30. Plaintiff fled the family home with Child T on May 14, 2015 for seven (7) days and
sought help through Safe Connections, which is the Saint Louis, Missouri region’s oldest and
largest organization working to educate, prevent, and end domestic and sexual violence while
helping survivors safely escape their abusers and thrive.
31. At Safe Connections on May 15, 2015, Child T reported that Stientjes “punched
Child A in the face” and that “Child A often ducks” when Stientjes hits him and Stientjes “pulls
Child A’s hair.” Child T also reported to Safe Connections that Stientjes instructed Child A “to hit
Plaintiff.” Safe Connections contacted the Department of Family Services (“DFS”) which started
an investigation.
32. Child T reported to DFS what he had disclosed to Safe Connections. Child A
reported to DFS that Stientjes name called him. Plaintiff reported to DFS that Stientjes hit Child A
in the face and that Child A and Stientjes had verbal altercations during which they threatened
each other with real guns, which Stientjes owned, used on weekends in the country, and kept
unlocked all over the family home.
33. From June 2015 through September 2015, Plaintiff futilely attempted to pacify
Stientjes in order to protect Child A and Child T. Plaintiff urged Child A and Child T to walk
away from explosive situations. Plaintiff sought to teach Child A and Child T to view a negative
situation as an opportunity to learn how to communicate effectively with people in the future under
threatening and stressful circumstances. Despite Plaintiff’s isolation from her family members and
friends by Stientjes, Plaintiff tried to instill in Child A and Child T a sense of security. Plaintiff
listened to and comforted Child A and Child T when they were hurt or scared by Stientjes.
34. In June 2015, with Safe Connection’s help, Plaintiff enrolled Child A and Child T
in therapy at Family Forward, a Saint Louis, Missouri based community organization which helps
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vulnerable children with comprehensive therapeutic and educational services to promote the
children’s health and safety. Plaintiff hoped that Child A and Child T would not grow up to be
abusive like Stientjes but grow up to understand the damaging consequences of the abuse, remain
kind, respectful, and learn to establish boundaries in abusive relationships in the future. Family
Forward assigned an experienced and dedicated licensed professional counselor (“Family Forward
LPC”) to help Plaintiff’s family with crisis intervention.
35. Stientjes immediately tried to halt this helpful therapy as soon as Child A began
responding to therapy by admitting to Stientjes that he should not “berate Plaintiff.” Stientjes told
the Family Forward LPC “that he did not think counseling was helping the family.” Child A
reported to the therapist that “dad thinks mom is crazy.” Child A said that “dad has a hot temper
and raises his voice to others.” Despite these remarks, Plaintiff encouraged Child A and Child T to
stay positive and strong and to focus on staying safe while being respectful of Stientjes.
36. In September 2015, Plaintiff’s family was spiraling through another “explosive
phase” when Child A started eating nonfood items. Stientjes forbid Plaintiff from taking Child A
to see a doctor.
37. Plaintiff shared her dire concerns with her Safe Connection’s counselor who
reported this to DFS. On September 10, 2015, DFS opened a case file and later found that the
allegations of child abuse and neglect were substantiated. Stientjes refused to sign and follow the
Safety Plan initially proposed by DFS. When DFS threatened to remove Stientjes’ parental rights,
Stientjes allowed Plaintiff to take Child A to see a doctor at which time Child A, at the age of
twelve (12), was diagnosed with Pica, an eating disorder involving eating nonfood items, such as
chair cushioning, wires, rubber, pencils and plastic items.
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38. On September 14, 2015, Child T reported to his Family Forward LPC, that “Child T
was confused about whether or not his nightmare about Stientjes raping Child T was true or not,”
which had happened the previous night. Plaintiff questioned Child T as to whether it was a
nightmare because Child T had nightmares regularly during Stientjes’ explosive phases of abuse.
The following week Child T again talked to his Family Forward LPC about “his dream of Stientjes
violating him.”
39. From September 2015 through November 2015, Child T learned the skills
necessary to tell Stientjes that he would not snuggle with Stientjes at night in the same bed. On
October 16, 2015, Child T told his Family Forward LPC that Stientjes “told Child T that ninety-
nine (99) percent of the world sucks dicks and lick each other’s kooters even if they don’t want to
do it.” Family Forward LPC diagnosed Child T with Post Traumatic Stress Disorder (“PTSD”)
and Anxiety due to domestic violence at home. Believing that Child T had nightmares of being
sexually abused, the Family Forward LPC did not report Child T’s problems to DFS.
40. The Family Forward LPC reported on October 23, 2015, that “Child A’s diagnose
of Pica has increased the tension in the home.” Child T reported to the Family Forward LPC that
Child A “was banging [Child A’s] head on the floor” during family arguments.
41. In November 2016, the Family Forward LPC diagnosed Child A with Oppositional
Defiant Disorder after seeing Child A seven (7) times. The therapist also noted that Stientjes came
to therapy and tried to persuade the therapist that “Plaintiff was not a good mother and his children
did not have problems that needed to be addressed.” The Family Forward LPC told Stientjes that
Child A required counseling. But Stientjes forbid Plaintiff to take Child A to therapy at Family
Forward and ordered Child A not to go to Family Forward with his mother. Plaintiff was still
allowed to continue with therapy for Child T at Family Forward.
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42. In September 2015, during its investigation of Child A’s PICA, DFS determined
that Plaintiff’s family needed further intervention requiring Child A to see a psychiatrist and the
entire family engage in ten (10) weeks of intensive in-home services (“IIS”) during which
Plaintiff’s family was to meet with a DFS therapist once or twice a week for several hours.
43. Plaintiff took Child A to see Doctor Vadim Baram, M.D. (Baram), a Board-
Certified Psychiatrist, who recommended that the parents engage in therapy with Child A with an
LCSW working in Baram’s office. The goal of the therapy was to address Child A’s Pica and
family turmoil because the family turmoil was one of the causes of Pica. Stientjes was unwilling
to have Child A treated. Stientjes engaged in therapy only after DFS made Stientjes sign a Safety
Plan demanding that Stientjes pursue the IIS plan and the treatment that Child A required.
44. The LCSW at Baram’s office documented that the DFS recommended IIS and
“Plaintiff is ready to proceed, but [Stientjes] is uncertain whether IIS is necessary at this time.”
The LCSW concluded that Plaintiff’s family dynamics have “indications of discord escalating to
physical violence.” In another session, the LCSW reported that “Child A uses name calling of his
mother [Plaintiff], interruptions and accusations” and that Child A reported that he could not
communicate with his mother without insulting her.
45. In December 2015, Child T created and reviewed his trauma narrative with the
Family Forward counselor where Child T said the following: “inside I feel that I’m living an
isolated life, with a family that fears my father;” “when my dad leaves on a business trip … that
my grandmother (my mom’s mother) spends time with us;” “we sneak her to the house when my
dad is not at home;” “dad has to give permission for everything we do;” “I live in the family where
there is no freedom;” “in the house we must keep the temperature below sixty-four (64) degrees
even if we’re freezing;” “in the winter we stay wrapped up in coats and blankets to stay warm;” “in
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the summer, the temperature is eighty-two (82) degrees we are constantly burning up.” “I use
icepacks to cool off;” “my dad is physically abusive;” “he calls my mother a worthless mother,
Russian slut, bad mother, dirty whore, crazy and more;” “my life is we are trying to escape being
hit by a bus;” “my dad is the bus driver;” “my dad would slam my brother against the wall;” “once
in a while he would hit me too;” “my brother lies because my brother fears my dad;” “fear travels
throughout this family;” “snuggling with each other was typical in my family at night;” “at night
my dad pulled me close;” “in my dream I remember seeing my dad’s distorted face, and his
genitalia up my anus;” “my bottom felt sore;” “my dad would tell my brother to hit my mother;”
“my mom was emotionally weak;” “counseling has helped me dramatically;” “my mom has the
courage to stand up to my dad;” and “under my dad’s power, my brother would lie to survive.”
46. Unfortunately, Plaintiff did not consider herself to be a victim of domestic violence
until she spent a whole year (May 2015-May 2016) in therapy at Safe Connections, where she
learned about domestic violence and the power and control dynamics within her marriage.
Plaintiff futilely tried to protect Child A and Child T, always tried to focus on the children’s
positive traits, taught the children to listen, tried to understand the children’s feelings, accepted
their concerns respectfully, and tried to use compromise and respectful negotiation skills.
47. When Plaintiff tried to stand up for Child A and Child T and herself, Stientjes
always blamed Plaintiff for his own endless anger. Stientjes yelled and screamed at everyone, that
Plaintiff was the reason that he was so angry all the time. Stientjes would tell Child A and Child T
that it was always her (Plaintiff’s) fault. Plaintiff continually tried to pacify Stientjes so he would
not physically and emotionally hurt Child A and Child T. Plaintiff often felt guilty and blamed
herself for not being able to protect Child A and Child T from Stientjes never ending abuse.
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48. In February 2016, Plaintiff’s family was in another “honeymoon cycle” during
which Stientjes persuaded Plaintiff, Child A and Child T, that he had changed, and Plaintiff should
not seek a divorce. During this short lived “honeymoon cycle,” Stientjes improved his relationship
with Plaintiff, Child A and Child T.
49. Child T reported to his Family Forward LPC that “there are few fights at home” and
that “he has not witnessed parental conflict.” Since the entire family was doing much better, Child
T’s therapy at Family Forward was suspended two (2) months later.
50. The LCSW, who was treating Child A at Baram’s office, also reported that at that
time, the family dynamics in Plaintiff’s home were stable.
51. During the “honeymoon phase,” Plaintiff and Stientjes purchased a condominium in
Florida so that the family could vacation there. The entire family travelled to Florida, including
Plaintiff’s Mother who previously was forbidden by Stientjes to visit Plaintiff’s home. At that
time, Plaintiff genuinely had hopes of saving her family and her marriage.
52. Sometime in April 2016, Stientjes told Plaintiff to get her driver’s license in Florida
so she could drive a car while the family stayed there. When Plaintiff obtained the driver’s license,
Stientjes told her that they would not file and pay their joint Missouri income tax although Plaintiff
and Stientjes lived full time in Missouri. Stientjes ordered Plaintiff to state that she would be a
resident of Florida, which Plaintiff considered untruthful.
53. Having learned that Stientjes wanted Plaintiff to do what Plaintiff believed violated
the tax laws, Plaintiff finally sought a divorce from Stientjes in July 2016; Cause No. 16SL-
DR04088, Saint Louis County, Missouri, Circuit Court.
54. During the divorce proceedings, Plaintiff learned for the first time that Stientjes did
not report Plaintiff’s income, from 2009 through 2014, on their joint tax returns. As a result,
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Plaintiff did not make any contributions to her Social Security fund and her pension plan.
Plaintiff’s credit was also materially damaged.
55. The couple’s divorce was granted on October 4, 2016. (All reference to “the Court”
hereafter is to the Court that presided over the dissolution case and subsequently over the child
custody modification proceedings, being case 16SL-DR04088-01).
56. Pursuant to the 2016 Dissolution Judgment, Petitioner and Stientjes, were awarded
joint legal and joint physical custody of Child A and Child T, then ages 14 and 13, respectively.
B. Family History That Led to Plaintiff Seeking Modification of Child Custody
57. In early 2017, Stientjes, during his joint custody time, abandoned Child T at eight
o’clock (8pm) in the evening in the dark outside the Clayton Center building, in Clayton, Missouri,
at as a form of punishment. Child T contacted Plaintiff, who picked him up and brought a cold and
frightened Child T to her home.
58. During his custody time, Stientjes endlessly berated Plaintiff in front of Child A and
Child T and called Plaintiff “a slut who needed a good dicking.” Stientjes engaged Child A and
Child T in inappropriate sex related conversations and took Child T and his fifteen (15) year-old
female friend to the Victoria Secret store to buy the fifteen (15) year-old female friend underwear
without her parents’ knowledge or consent. During an overnight trip to Illinois with Child T and
his fifteen (15) year-old female friend, Stientjes stayed in the same hotel room with the minor
children and Stientjes took both minor children to an adult sex store again, without her parents’
knowledge and consent.
59. Stientjes encouraged Child A and Child T to be disrespectful towards Plaintiff and
repeatedly told the children that they did not need to respect Plaintiff or follow the Parenting Plan
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ordered by the Court. After each visitation with Stientjes, Child A and Child T returned to
Plaintiff aggressive, disrespectful, hostile, and belligerent.
60. A physical altercation between Child T and Stientjes erupts in late January 2017,
during which Stientjes kicked Child T as Child T was lacing his shoes. Stientjes told Child T that
he no longer wanted custody of Child T and threw Child T’s belongings outside of his house.
61. After this incident, Plaintiff continued to follow the Parenting Plan and encouraged
Child T on several occasions to go to Stientjes house. Stientjes repeatedly told Child T, upon
arrival at his house, that Child T was not welcome. In March 2017, Child T stopped going to
Stientjes’ house for scheduled custody time.
62. In March 2017, Stientjes stopped abiding by any terms of the Court ordered
Parenting Plan and relocated Child A to Defiance, Missouri without giving Plaintiff and the Court
the Relocation Notice required by Missouri law and the divorce decree. In July 2017, Stientjes
initiated a change of schools for Child A from Saint Louis County, Missouri to St. Charles County,
Missouri.
63. In March 2017, Stientjes refused to cooperate with Plaintiff in preparing the
couple’s joint tax return for the year 2016 as was required by the Dissolution Judgment. Stientjes
who had prepared the couple’s tax returns during the entire marriage, refused to provide Plaintiff
with the documents necessary for Plaintiff to prepare and file her own tax returns unless Plaintiff
signed a side agreement stating that Plaintiff and Stientjes would give their children freedom in
following the custody arrangements established in the Parenting Plan.
64. Plaintiff felt as if she had no choice but to sign the side agreement in order to get
her tax returns completed and filed because she was applying for a loan to refinance a house loan
which the bank refused to process unless Plaintiff had her 2016 returns filed.
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65. At all relevant times hereto, Plaintiff has been a nurturing and loving parent to
Child A and Child T. Plaintiff took Child A and Child T to their doctors for all their regular and
emergency appointments and took care of Child A and Child T when they were sick. Plaintiff
helped Child A and Child T with their academic assignments. Plaintiff enrolled and engaged the
children in many extra-curricular activities aimed at developing and supporting their academics,
interests and hobbies, encouraged them to work on their differences and to accept each other’s
interests, while trying to build their trust and understanding of the difficult and explosive family
dynamics.
66. After each visit with Stientjes during joint custody, Child A and Child T were filled
with anger and aggression. Plaintiff tried to re-enroll Child A and Child T with the Family
Forward LPC in January 2017, but Stientjes contacted the Family Forward LPC and told her that
she did not have his permission to counsel either child.
67. In January 2017, Plaintiff found another therapist at Provident Behavioral Health,
one of the oldest non for-profit community-based organizations that provides mental health
services to the residents of Metropolitan Saint Louis area. A Provident LPC started counseling
Plaintiff, Stientjes, and both children how to cope with the divorce and custody arrangements.
Through Provident, Plaintiff wanted Child A and Child T to learn coping and boundary setting
skills and to learn to acknowledge and process their feelings, and experiences.
68. The Provident LPC reported that “dad does not want to participate in therapy;”
“Child A was disrespectful to mom [Plaintiff] and called her vulgar names;” “Child A continues to
have cognitive distortions;” and “continues to see things in extremes;” “shows signs of distress,
distrust and hurt evident by tearfulness;” “mom begs Child A to have a relationship with her;”
“Child A was very disrespectful to mother in session, calling her names;” “Child A continues to be
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oppositional with counselor arguing with most comments made, expressing distrust and borderline
paranoia with counselor, when counselor attempts to teach a skill;” “Child A lacks empathy,
compassion, forgiveness, understanding and has replaced the mentioned qualities with one strike
and you’re out mentality;” “Child A has lots of anger and was expressing anger in the session;”
and “Child A continues to have rage towards Mother.” In response to Child A, the Provident LPC
explained that “the purpose of therapy is reunification. Not humiliation, power and control.”
69. In March 2017, Stientjes prohibited Child A from having any contact with Plaintiff
and Stientjes interfered with Plaintiff’s attempts to see Child A.
70. On August 8, 2017, the Provident LPC reported that “mom [Plaintiff] is willing to
move forward” with family healing, while Stientjes “expressed a strong resentment that does not
allow him to move forward.” The therapist reported that Stientjes “could not” and “did not” accept
“the idea that at times a parent needs to have rules and enforce them.” Stientjes stated that “he did
not trust [mom] and if Stientjes does not trust mom, Child A will not either.” In August 2017, the
LPC, that counseled the family, left Provident. Stientjes informed Plaintiff that he would not
allow, under any circumstances, Child A and Child T see another therapist at Provident.
71. As a result of Stientjes’ actions, Plaintiff initiated the child custody modification
proceedings on August 8, 2017.
72. During the divorce, Child A had four (4) disciplinary school reports. After the
divorce, Child A had three (3) additional disciplinary reports for which he was suspended. Child
A showed non-compliance with a teacher’s request, used his phone when it was not allowed and
ran inside the moving school bus. The last incident involved Child A stealing his teacher’s
identity, opening an Instagram account with the teacher’s name, and disseminating messages and
pictures from that account to the teacher’s student body.
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73. On August 30, 2017, Child T reported to the school counselor that Stientjes
sexually violated him. The school counselor made a referral to DFS. As part of the referral, Child
T was interviewed by a State of Missouri Forensic Psychologist and Olivette Police who both
found the disclosure was credible. They referred the case for prosecution to the Saint Louis
County prosecutor, who declined to investigate and prosecute the allegations of abuse brought by
Child T against Stientjes.
74. In September 2017, Plaintiff enrolled Child T at Safe Connections to help him heal
from the trauma inflicted by Stientjes.
75. On August 30, 2017, the Court appointed Pudlowski to serve as GAL in the child
custody modification proceedings. A copy of Pudlowski’s Appointment Order is attached as
Exhibit 1 and made a part thereof.
76. Pursuant to this Order, Pudlowski was to be guided by the best interests of Child A
and Child T and to exercise independent judgment in formulating and presenting recommendations
to the Court.
77. Pudlowski was also to adhere to applicable statutes, rules and regulations relating to
receipt and redisclosure of privileged information received as a GAL and “to review the progress
of the minor children’s case and advocate for timely hearings, necessary services for the minor
children and compliance with the family court orders.” [emphasis added].
78. The Court also required Pudlowski “to participate and monitor service plans,
parenting plans, proposed orders and staffing affecting the best interests of the minor children as
well as strive to protect the interests of the minor children and inform the family court of the
minor children’s wishes.”[emphasis added].
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79. At the conclusion of the case, Pudlowski was to file a “Memorandum of
Compliance” with the Court acknowledging that she “complied with the Missouri Supreme Court
Standards for GAL.” Pudlowski never complied with these standards, nor did she ever file the
required Memorandum of Compliance.
C. Facts Related to Breach of the Standard of Care and Contract by Defendant Reid
80. On October 3, 2017, Stientjes petitioned the Court to appoint a psychologist to
evaluate Plaintiff’s mental health. Plaintiff subsequently asked for a psychological evaluation of
Plaintiff, Stientjes, Child A and Child T.
81. On October 26, 2017, Pudlowski asked the Court to appoint Reid as an independent
forensic psychologist to evaluate the mental health of Plaintiff, Stientjes, Child A and Child T.
82. Prior to Reid’s appointment in case 16SL-DR04088-01, Reid served as the forensic
family psychologist in excess of twelve (12) other family custody cases in which Pudlowski was
the GAL and had also recommended Reid evaluate the parenting abilities of the parties.
83. On October 26, 2017, the Court Order appointing Reid specified:
a. Reid should “evaluate the psychological status of Petitioner, Stientjes, Child A and
Child T, and to assess any allegations or issues regarding their current mental health
and the parenting ability of each parent specific to this case bearing on the best
interests of the children. The Evaluator shall offer opinions and recommendations
regarding this case.”
b. Reid should act “as a forensic psychological expert, not as a mediator, parenting
coordinator or psychotherapist.”
c. “the parties and children” were not to become Reid’s patients and they “do not
acquire the rights of patients by their participation in the evaluation.”
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d. Reid was to “exercise his independent objective judgment in conducting the
evaluation.” [emphasis added].
e. “Each party retain[ed] the right to argue the issue of weight, sufficiency and
reliability of such evidence.”
f. “the parties and counsel, except for GAL … [were] prohibited from telling the
minor children what is contained in the report, … or to receive the information
concerning the report from any source whatsoever.”
g. Reid was required “to provide to each counsel a ‘complete copy’ of his entire file
(including psychological test data)” and to “cooperate in affording access to the
file” “without any further order or subpoena” while “charging for copies as
specified in RSMo 191.227.” Reid was allowed “to charge reasonable fees for all
professional time, services … and expenses.”
84. Reid demanded that Plaintiff sign a Statement of Understanding (“SOU”), drafted
by Reid, which was Reid’s contractual commitment to Plaintiff as well as Plaintiff ‘s to Reid,
before Reid would undertake his Court appointment. Pursuant to the SOU, Plaintiff was to benefit
from Reid’s “impartial evaluation” in which Reid was “expected to secure verification of
assertions made by those whom [he was] evaluating.” [emphasis added]. A copy of the SOU is
attached as Exhibit 2 and made a part of this petition.
85. In Reid’s SOU, Reid guaranteed the following:
a. to “conduct a psychological evaluation of Petitioner [Tolu] and Respondent

[Stientjes], … and their minor children, and to assess any allegations or issues
regarding their current mental health and the parenting ability of each parent
specific to this case bearing on the best interests of the children;” [emphasis
added]
b. “to conduct an impartial evaluation;” pursuant to the Court’s Order.
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c. “impartial evaluators are expected to operate as though they were employed by the
court.”
d. “[f]orensic psychologists are expected to secure verification of assertions made by

those whom they are evaluating.” “verification of the information provided by you
can be sought and the other party can be afforded the opportunity to respond to
allegations that have been made.”
e. “You are not expected to pay for services that have never been performed.”
f. “[Reid] cannot provide psychological advice to individuals whom [he is]

evaluating.”
g. “[Reid is] obligated to maintain his impartiality and openness to new information.”
“Any documents submitted to me must be sent to me by the attorneys and must be
accompanied by a statement verifying that the submitted items are simultaneously
provided to other attorneys involved in the case.”
h. “[Reid] was also “obligated to maintain [his] impartiality and openness to new
information throughout the course of [his] evaluation.
86. On November 11, 2017, Plaintiff also signed an Informed Assent drafted by Reid to
allow Reid to proceed with the psychological evaluations ordered on October 26, 2017. Pursuant
to the Informed Assent, Reid was to conduct testing, interviews, investigations, and document
reviews and “conduct an objective evaluation.” [emphasis added]. A copy of the Informed Assent
is attached as Exhibit 3 and made a part of this petition.
87. Reid met with Plaintiff five (5) times, from December 12, 2017 through January 22,
2018, engaging in various interviews, psychological testing, and communications.
88. Reid met with Stientjes six (6) times, from December 12, 2017 through January 19,
2018, engaging in various interviews, psychological testing, and communications.
89. Reid met with Child A on January 15, 2018 and Child T on January 22, 2018,
engaging in various interviews, psychological testing, and communications.
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90. Through April 2, 2018, Reid also engaged in interviews and communications with
the parents’ witnesses, being people who the parents stated could verify their parenting skills and
parental styles as well as their weaknesses and strengths.
91. Reid was actively involved in Plaintiff’s case, from October 26, 2017 through
November 2, 2019.
92. On March 28, 2018, Pudlowski filed a Motion to Limit Release of the Reid Report
only to the parents’ attorneys involved in the case.
93. On April 3, 2018, Reid released his Reid Report to Pudlowski, even though Reid
was not yet ordered to do so.
94. Reid received a total of thirty thousand dollars ($30,000.00) of which Plaintiff and
Stientjes each paid half toward the Reid Report before its release, on April 3, 2018, to Pudlowski.
95. On April 5, 2018, the Court ordered the release of the Reid Report only to
Pudlowski. Pursuant to the Court’s order, Pudlowski was allowed “to re-release the report only to
the parents’ attorneys.” [emphasis added]. A copy of the Order is attached as Exhibit 4 and made
a part of this petition.
96. Pudlowski had not released the Reid Report to any other person before the Court
issued this Order on April 5, 2018.
97. On April 10, 2018, Plaintiff filed her Motion to Strike the Reid Report because it
did not comply with the October 26, 2017 Court Order appointing Reid “to conduct a
psychological evaluation of Petitioner [Plaintiff] and Respondent [Stientjes], and their minor
children, and to assess any allegations or issues regarding their current mental health and the
parenting ability of each parent specific to this case bearing on the best interests of the children”
and “offer opinions and recommendations regarding this case.” Reid was instructed several times
22
by attorneys, for both Plaintiff and Stientjes, not to make a custody recommendation, but Reid did
in fact make custody recommendations.
98. Reid did not undertake a psychological evaluation of Plaintiff and Stientjes, but
instead performed a custody evaluation. Reid made his own custody determination in violation of
the Court’s Order. Reid also concluded that Plaintiff alienated Child T from Stientjes, but Reid did
not conclude that Stientjes alienated Child A from Plaintiff nor did he recognize or identify any
symptoms of domestic and intimate partner violence.
99. Despite the statement in the SOU that “[i]t must be understood that I [Reid] cannot
provide psychological advice to individuals whom I am evaluating,” Reid without justification, in
violation of the standard of care, violating the Court’s mandate and his SOU that he be objective,
and outside the scope of his evaluation, diagnosed Plaintiff with various disorders and
recommended Plaintiff undergo Dialectical Behavioral Therapy, which is “somewhat helpful to
individuals with significant personality pathology. However, change tends to be slow in coming, if
at all.” The Court did not authorize Reid to diagnose or develop a treatment plan for Plaintiff.
Reid did not recommend Plaintiff cease counseling at Safe Connections.
100. On April 24, 2018, the Court struck portions of the Reid Report containing Reid’s
custody recommendations.
101. On April 8, 2018, Plaintiff asked Reid to provide her with a complete copy of his
file pursuant to the October 26, 2017 Court Order which allowed Reid to charge for copies of his
file pursuant to RSMo 191.227. That statute provides that if the records are furnished
electronically, the provider of the records cannot charge more than one hundred eight dollars and
eighty-eight cents ($108.88) for this request.
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102. Although all of Reid’s records were stored in electronic format, Reid refused to
provide to Plaintiff his complete file unless Plaintiff paid Reid two thousand nine hundred sixty-
eight dollars and forty-eight cents ($2,968.48).
103. From April 8, 2018 through May 30, 2018, on five (5) separate occasions, Reid
refused to provide Plaintiff with his complete file and refused to afford Plaintiff access to his file in
violation of the October 26, 2017 Court Order. Reid knew that he was interfering with Plaintiff’s
expert’s review of his work in a timely manner before the trial.
104. Plaintiff and Stientjes paid Reid one thousand four hundred eighty-four dollars and
twenty-four cents ($1,484.24) each, for a total of two thousand nine hundred sixty-eight dollars
and forty-eight cents ($2,968.48), for Reid’s file on May 30, 2018, under extreme duress and the
stress imposed by the upcoming trial.
105. On June 1, 2018, Plaintiff received Reid’s file which Plaintiff provided to her expert
psychologist, Doctor Williger. The file Reid turned over was significantly incomplete. For
example, it did not have any data from Parental Assessment Inventory and only had MMPI test
answers provided by Plaintiff and Stientjes. It did not contain video recordings, that Reid claimed
he was making of every meeting, with Plaintiff, Stientjes, their children and the people he
interviewed on behalf of Plaintiff and Stientjes.
106. On numerous occasions, during Plaintiff’s meetings with Reid, Reid called Plaintiff
“a drunk” and “an alcoholic,” even though Reid knew that Plaintiff does not drink alcoholic
beverages. Reid called Plaintiff “a bad mother” and “a liar.” Reid accused Plaintiff of “perjuring
the court,” “defrauding court,” “defrauding an adoption agency,” “misleading the court,” “lying to
her attorney,” being “deceitful,” and “manipulative.” All of Reid’s accusations were untrue and
24
demonstrated extreme bias and violated professional standard of care and the Court’s Order
appointing him.
107. Hearing these insults from Reid, Plaintiff was stunned and intimidated. Tears ran
uncontrollably from Plaintiff’s eyes during each session with Reid. Reid falsely accused Plaintiff
of “using tears as act of manipulation.” Being intimidated, Plaintiff was unable to defend herself
from Reid’s outrageously false accusations. Moreover, one time when Plaintiff tried to challenge
Reid’s outrageously false accusations, Reid cut Plaintiff off saying he was not interested in
Plaintiff’s “stupid stories about not being a drunk and a liar.” On January 2, 2018, Reid’s insults
became so outrageously abusive, that Plaintiff ran to Reid’s bathroom to vomited violently.
108. During Reid’s interviews with Plaintiff, Reid told Plaintiff each time that “he made
audio and video recordings of all his meetings with her (Plaintiff), Stientjes and their sons.”
109. While reviewing Reid’s file, Plaintiff learned that the length of time of Reid’s audio
files did not match the length of time Reid billed for them.
110. Reid’s records show numerous length of time differences between his audio
recordings and the billing entries he made. For example:
a. On December 12, 2017, Reid billed Plaintiff for twenty-six (26) minutes more than
the length of time of his audio recording;
b. On December 18, 2017, Reid billed Plaintiff for two (2) hours and fifty-one (51)
minutes more than the length of time of his interview with Plaintiff;
c. On December 27, 2017, Reid billed Plaintiff for thirty-nine (39) minutes more than
the length of time of his audio recording;
d. On January 2, 2018, Reid billed Plaintiff for fifty-five (55) minutes more than the
length of time of his audio recording.
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111. A comparison of Reid’s billing entries to the audio recordings of Stientjes, Child A,
Child T and parents’ witnesses revealed an additional twelve (12) other differences between the
length of time of the audio recordings and what Reid billed Petitioner and Stientjes.
112. Reid’s audio tapes were mysteriously missing extremely disparaging and abusive
insults, and accusations directed toward Plaintiff, even though Reid said he recorded everything.
At no time during the meetings did Plaintiff observe Reid turn on or turn off any audio or video
recording devices.
113. Reid’s audio tapes did not contain other vital information Plaintiff provided to Reid
during their sessions pertaining to Stientjes’ moral character, such as:
a. Stientjes’ right to represent taxpayers before the IRS was curtailed through IRS
disciplinary suspension proceedings;
b. Stientjes was sued by a former client for misappropriating twenty-one thousand
dollars ($21,000.00) held in Stientjes’ IOLTA trust account;
c. Stientjes was a target of a criminal tax investigation;
d. Stientjes underreported Plaintiff’s income on the couple’s joint tax returns for five
(5) years during Plaintiff’s marriage to Stientjes, and reported Plaintiff’s income as
his own, depriving Plaintiff of her earned social security benefits, pension
contributions, and materially damaging Plaintiff’s credit rating;
e. Stientjes’ relocated Child A to Defiance, Missouri in violation of the Court ordered
Parenting Plan (Stientjes never gave Plaintiff and the Court the statutorily required
relocation notice);
f. Stientjes’ defrauded a Saint Louis bank in a real estate transaction; and
g. Stientjes provided untruthful sworn court testimony in several federal cases.
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114. Reid told Plaintiff that Plaintiff was audio and video recorded to make sure Plaintiff
was not “cheating.” Yet, Plaintiff’s expert found that even shortened versions of Reid’s audio
recordings showed that Reid was a biased, nonobjective evaluator and he consistently violated the
appropriate standard of care.
115. Learning of audio tape spoliation, Plaintiff requested that Reid produce all original
audio and video recordings that Reid said that Reid was making of every interview meeting as
required by the October 26, 2017 Court Order and the Informed Assent and for which Reid was
paid two thousand nine hundred and sixty-eight dollars and forty-eight cents ($2,968.48). Reid
refused to provide Plaintiff with the original audio and video recordings.
116. On July 27, 2018, Plaintiff filed a Motion for Production of Reid’s Original Audio
& Video Recordings of Reid’s Interviews to compare them to Reid’s produced audio recordings.
117. Reid responded to the motion admitting that he altered the recordings when Reid
“cut” and “pasted” the recordings into his computer and that the Washington University
Psychological Center (Washington University) “destroyed all the video recordings of the
interviews.” Later, mysteriously, two video recordings did surface, one being with Child T and the
other with Plaintiff’s current spouse, Kowalski. The video recordings were on the Washington
University servers.
118. Neither Plaintiff, nor more importantly, the Court ever authorized Reid to “cut”,
“paste”, delete or alter any of Plaintiff’s files during the pendency of the child custody litigation or
at any other time. In doing so, Reid violated the Court’s October 26, 2017 Order and Missouri
evidence spoliation law.
119. On August 3, 2018, the Court ordered Reid to produce his original files including
the original audio and video recordings.
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120. Reid refused and continues to refuse to comply with the August 3, 2018 Court
Order and continues to violate the October 26, 2017 Court Order that required Reid to produce his
complete file of the evaluation of Plaintiff, Stientjes and their two minor children, including the
audio and video recordings “without any further order or subpoena” to Plaintiff.
121. After reviewing the material Reid produced, Doctor Williger, Plaintiff’s expert
psychologist, concluded that Reid failed to use the degree of skill and learning, ordinarily used
under the same or similar circumstances by the members of Reid’s profession when performing a
forensic psychological evaluation within the parameters of the Court Order appointing Reid:
a. by failing to conduct an acculturation measure pertaining to Plaintiff’s background
when administering an MMPI evaluation, which nullified the Reid Report with
regard to Plaintiff from its inception;
b. by sharing Plaintiff’s documents with Stientjes without Plaintiff’s knowledge and
consent and in violation of Defendant Reid’s own SOU as described in paragraphs
84-85 above;
c. by concealing from Plaintiff, Stientjes and the Court, objective psychological test
data for Plaintiff and Stientjes;
d. by omitting and not investigating and not considering Child A’s numerous medical
and special needs conditions;
e. by concealing from Plaintiff and the Court, objective testing for Stientjes revealing
that Stientjes is “forceful and controlling;” “characterized by poorly controlled
anger that is expressed in cyclical fashion;” “the cyclic periods of outbursts with
intermittent periods of appropriate behavior represents a chronic and stable
personality disorder that is extremely difficult to change;” “defensive, guarded, and
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unwilling to acknowledge psychological problems even when they are readily
apparent to others.”
f. by ignoring Stientjes’ high score on the Over Controlled Hostility Scale showing
that Stientjes had the personality style of chronic hostile behavior;
g. by failing to investigate domestic violence by Stientjes towards his children
reported by his children, and consistent with therapists’ records and DFS reports;
h. by baselessly diagnosing Plaintiff with mental health disorders contrary to the
MMPI and Plaintiff’s therapists and past history;
i. by failing to investigate Stientjes’ moral character;
j. by failing to use standard methodology used by members of Reid’s profession in
conducting forensic evaluations involving child custody proceedings;
k. by being biased, confrontational, derisive, sarcastic, and disrespectful to Plaintiff;
l. by failing to follow numerus other standards and required practices used by
members of Reid’s profession when investigating and producing reports called for
in the Court Order appointing Reid; and
m. by failing to seek peer review which was required in Plaintiff’s case once Reid
knew that he was biased.
122. To prepare for trial, Plaintiff subpoenaed Reid for a deposition.
123. Reid requested that Plaintiff pay Reid five thousand dollars ($5,000.00) for four (4)
hours of his deposition time, when Reid’s SOU states that he charges three hundred fifty dollars
($350.00) per hour for deposition time.
124. On August 28, 2018, Plaintiff paid Reid five thousand one hundred dollars
($5,100.00) for Reid to attend his deposition set for September 14, 2018.
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125. On September 13, 2018, Reid informed Plaintiff’s counsel that he would not be
deposed unless Plaintiff paid Reid three thousand two hundred and forty-four dollars ($3,244.00)
in addition to the five thousand one hundred dollars ($5,100.00) previously paid by Plaintiff on
August 28, 2018.
126. Plaintiff did not have time to challenge Reid’s unreasonable fees because Plaintiff’s
trial was set to begin in three (3) days and the Court could not hear Plaintiff’s motion regarding
Reid’s fees on such short notice. Reid knew this and exploited Plaintiff’s circumstances when
Reid demanded excessive compensation.
127. On September 14, 2018, at Reid’s deposition, it became apparent that Reid could
not even answer the most basic questions as shown by the following examples:
a. When asked what fraudulent document Plaintiff provided to Reid, Reid answered,
“I can’t remember exactly.”
b. When asked what documents provided to Reid were fraudulent according to
Stientjes, Reid answered, “I can’t recall.”
c. When asked how many times Plaintiff asked Reid for documents, Reid said, “I
don’t remember.”
d. When asked why Reid made a custody determination, Reid said, “I don’t know
why.”
e. When asked if Reid knew that Stientjes relocated Child A in violation of the Court
ordered Parenting Plan, Reid responded, “I don’t know.”
f. In the Reid Report, Reid stated that during the marriage, Plaintiff was never home.
When asked where Plaintiff was during her marriage, Reid said, “I don’t know” and
“I didn’t ask.”
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g. When asked whether Reid received any pleadings, Reid said, “no,” but later said, “I
am changing my answer now.”
h. When asked whether Child A stole his teacher’s identity, Reid answered, “I don’t
remember.”
i. When asked how many hours Reid spent reviewing Plaintiff’s records, Reid
responded, “I don’t have a photographic memory.” When reminded that he spent
three (3) hours reviewing records, Reid said, “I don’t remember items specifics” and
it “was not my job.”
j. Reid said that Child A was never diagnosed with Pica, but later he said that “child
has unusual chewing disorder” and “it was significant pathology.”
128. After Reid charged Plaintiff eight thousand three hundred and forty-five dollars
($8,345.00) to attend his deposition, Reid did not know the contents of his report and was able to
provide only limited answers to Plaintiff’s counsel’s questions on specific sections of his report.
Reid appeared lost, confused, forgetful and contradicted the Reid Report on numerous instances.
129. On September 14, 2018, Plaintiff’s expert, Doctor Williger, testified at a deposition
that Reid failed to use the degree of skill and learning ordinarily used under the same or similar
circumstances by forensic psychologists providing evaluations in family court proceedings
involving divorce and child custody modifications for the reasons stated above in paragraph 121,
in violation of the standard of care.
130. On May 20, 2019, Plaintiff served Reid with a document subpoena asking him to
produce the copies of Plaintiff’s complete file including emails, text messages, audio recordings,
video recordings and hard copy documents from his work on Plaintiff’s case from May 2018 to
June 10, 2019. Reid refused to comply with the subpoena.
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131. On June 24, 2019, Plaintiff filed a Motion to Compel Reid to produce his file and
for Sanctions for failing to comply with the subpoena.
132. In response to the subpoena, Reid emailed Plaintiff’s counsel a list of his current
cases, but refused to produce any other subpoenaed documents, unless Plaintiff paid Reid another
five hundred dollars ($500.00) in addition to one hundred dollars ($100.00) already paid by
Plaintiff. This demand by Reid was in violation of the October 26, 2017 Court Order.
D. Facts Related to the Breach of Fiduciary Duty by Defendant Pudlowski
133. Pursuant to the August 30, 2017 Court Order appointing Pudlowski, Plaintiff
provided Pudlowski Plaintiff’s releases authorizing Pudlowski to obtain Child A and Child T’s
DFS, medical, therapy and school records, as well as the Olivette Police Report. Pudlowski
received these documents but ignored the content of these records and failed to inform the Court as
to their existence.
134. On August 7, 2018, Pudlowski filed a proposed order with the Court, asking the
Court to appoint Van Luven to conduct “reunification therapy” for parents’ minor Child A and
Child T and to release the Reid Report to Van Luven. The Court never granted Pudlowski’ s
proposed order. Pudlowski never had authority to release the Reid Report to Van Luven.
135. Sometime in August 2018, Pudlowski told Plaintiff and Stientjes to begin therapy
with Van Luven, although there was no Court Order appointing Van Luven at that time. Plaintiff
saw Van Luven on August 23, 2018 and during this meeting, Van Luven showed Plaintiff the Reid
Report and told her that she just received it by email from Pudlowski but that she had not yet read
it.
136. The release of the Reid Report by Pudlowski was in violation of the April 5, 2018
Court Order which allowed Pudlowski to release the Reid Report “to parties’ attorneys only,” the
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October 26, 2017 Court Order that allowed Reid to release his report to Pudlowski only, and the
August 25, 2017 Court Order which required Pudlowski to comply with “the applicable statutes,
rules and regulations relating to receipt and redisclosure of privileged information” she received as
the GAL. The September 18, 2018 Court Order confirmed the previous three (3) referenced
Orders.
137. Plaintiff never consented to the release of the Reid Report to Van Luven. Van
Luven never sought Plaintiff’s consent to accept, read and use the Reid Report during Van Luven’s
therapy.
138. During the custody proceedings, Child T disclosed to Pudlowski that Stientjes has
been involved with Child T’s fifteen (15) year old female friend, who comes from a family that
struggles financially and that Stientjes showed some inappropriate behavior towards this fifteen
(15) year old girl doing the following:
a. Stientjes purchased gifts for this fifteen (15) year old girl and for her parents, he
gifted them a car;
b. Stientjes took this fifteen (15) year old girl to his house in Defiance, Missouri when
Child T was not there;
c. Stientjes commented on how beautiful this fifteen (15) year old girl was in front of
Child A and Child T;
d. Stientjes placed both his hands on this fifteen (15) year old girl’s shoulders, ran his
fingers through her long blond hair, and massaged her arm with his fingers;
e. Stientjes took this fifteen (15) year old girl to an adult sex store and a Victoria
Secret store; and
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f. Stientjes commented on this fifteen (15) year old girl’s breasts in the presence of
Child A and Child T.
139. Pudlowski never investigated or reported Stientjes’ inappropriate grooming
behavior of this fifteen (15) year old girl to the Court.
140. On September 17, 2018, the Court removed the case from the trial docket and
denied Pudlowski’ s proposed order filed on August 7, 2018 that would have allowed Pudlowski to
release the Reid Report to Van Luven. The Court, however, ordered the parents’ children to attend
reunification therapy with Van Luven, and the entire family to attend reunification therapy with
Erika Ottolini, LCSW. The Court did not allow Pudlowski to share the Reid Report with anyone
except the parents’ attorneys.
141. The Court’s Order stated that “[both children] [should] work on reestablishing their
relationship by continuing to meet with Jennifer Webbe Van Luven for joint therapy. [Child A]
and Petitioner shall begin therapy with … Erika Ottolini. [Child T] and Stientjes shall begin
therapy with Erika Ottolini.” The Court stated “the goal of the … therapy is primarily to focus on
reestablishing the relationship between [Child A] and [Child T], the secondary goal is to
reestablish the relationships between the children and the parents” and “to reunify the family and
to improve relationships within the family.”
142. On or after September 18, 2018, Plaintiff contacted Van Luven to discuss the
September 18, 2018 Court ordered therapy. Van Luven told Plaintiff that she had read the Reid
Report and that she would not discuss with Plaintiff, her, and the children’s therapy. Van Luven
ceased all contact with Plaintiff.
143. Van Luven’s actions were in violation of the September 17, 2018 Court order in
which both Van Luven and Ottolini were appointed “to reestablish relationships between the
34
children and the parents” and “to reunify the family and improve relationships within the family.”
These actions made it therapeutically impossible for her to establish a therapeutic relationships
with Plaintiff. Van Luven did not report her unwillingness to have any contact with Plaintiff to the
Court which appointed her.
144. At the same time, Pudlowski told Plaintiff to start therapy recommended by Reid
which was not sanctioned by the Court’s Order appointing Reid. Pudlowski threatened that if
Plaintiff did not terminate her and Child T’s therapy at Safe Connections, Pudlowski would
consider Plaintiff “a non-cooperating parent” and recommend that she suffer the total loss of
custody of both Child A and Child T. These actions violated the August 30, 2017 Court Order
appointing Pudlowski. Threatening Plaintiff with loss of custody of both Child A and Child T was
not in the best interest of both Child A and Child T. Demanding termination of Child T’s therapy
at Safe Connections, which the Safe Connections therapist told Pudlowski was helpful to Child T,
was also not in the best interest of Child T.
145. On October 5, 2018, Stientjes filed a Motion to Release the Reid Report to Van
Luven and Ottolini. Plaintiff timely objected on October 8, 2018 to Stientjes Motion to Release
the Reid Report to Van Luven and Ottolini.
146. The Court never granted Stientjes’ Motion to Release the Reid Report to Van Luven
or Ottolini.
147. On November 13, 2018, Pudlowski released the Reid Report to Ottolini in violation
of the August 30, 2017, October 26, 2017, April 5, 2018, and September 18, 2018 Court Orders.
Plaintiff never consented in writing for the Reid Report to be released. After receiving the Reid
Report, Plaintiff’s counsel consistently contested it and sought for it to be stricken.
35
148. Pudlowski threatened Plaintiff that if she did not consent to Ottolini receiving the
Reid Report, that she would again report Plaintiff as “a non-cooperating parent” and seek to
terminate any custody Plaintiff had or might gain with both Child A and Child T. This action by
Pudlowski was beyond her duties as a GAL, abuse of her mandate and a brazen attempt to coerce
Plaintiff to agree to release of Reid Report in an effort to circumvent the Court’s Orders
enumerated above and manipulate around her failure to gain the Court’s consent to the release of
the Reid Report to either therapist.
149. During the entire custody proceedings, Reid, Pudlowski and Van Luven ignored
and outright refused to investigate well documented domestic violence by Stientjes. Reid,
Pudlowski and Van Luven had complete records from DFS, medical records from the children’s
physicians and their therapists.
150. Instead, with no evidence to support their accusations, Reid, Pudlowski and Van
Luven blamed Plaintiff “for staging the abuse” by manipulating the doctors, the therapists and the
DFS for many years before Plaintiff filed for her divorce. In doing so, Reid, Pudlowski and Van
Luven violated the standard of care for their professions, HIPPA and numerous Court orders cited
above.
E. Facts Related to the Breach of the Standard of Care & Fiduciary Duty by Defendant Van
Luven
151. Van Luven did not try to reunify Child A and Child T, and to use the degree of skill
and learning, ordinarily used under the same or similar circumstances by members of Van Luven’s
profession engaged in court ordered family reunification therapy.
152. Van Luven breached the obligations conferred on her by the September 17, 2018
Court Order “to reunite Child A and Child T” and “to reestablish the relationships between parents
and the children.”
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153. Child T continuously told Plaintiff that the atmosphere during Van Luven’s therapy
was hostile, intimidating, and threatening and it fueled Child A’s anger towards Child T and
Plaintiff. On September 2, 2018, Van Luven told Child T that her job was not to fix the children’s
relationships with their parents even though the Court Order identified the parent child
reunification as a secondary goal.
154. On September 6, 2018, during Van Luven’s second meeting with the children,
Child A began verbally attacking Child T and berating Plaintiff. Van Luven encouraged Child A’s
anger stating that although “we're not here to bash parents or anything like that, but I think truths
need to come out.” Van Luven never pursued “the truth,” but only her bias, preconception of what
she wanted to believe.
155. During the same session, Child A disclosed Plaintiff’s diagnosis that was contained
in the Reid Report to Van Luven and Child T. Van Luven discussed Plaintiff’s diagnosis with the
Child A and Child T in violation of several Court Orders. Van Luven did not report this breach of
confidentiality, of Plaintiff’s Protected Health Information to the Court, to Plaintiff or to
Pudlowski. Van Luven did nothing to diminish or compensate for this harmful disclosure.
Instead, she exacerbated the harmful effects of this disclosure in her reunification sessions with
Child A and Child T.
156. During each counseling session thereafter, Van Luven demanded that Child T
confess that Plaintiff was distorting the truth [about domestic violence] and demanded Child T to
“agree on what [really] happened.” [emphasis added]. In the same session Van Luven told Child
A and Child T, “I don't know that you'll ever be able to reconcile with the other parent. I think
you're both satisfied with the living situation that you're both in.” (At that time Child T lived with
Plaintiff and Child A lived with Stientjes). [emphasis added]. The purpose of Van Luven’s
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therapy was to reunite Child A and Child T and to improve the children’s relationship with both
parents through reunification counseling.
157. On September 29, 2018, Van Luven pressured Child T to visit his brother (Child A)
in Defiance even after Child T reported to Van Luven that having experienced sexual abuse from
Stientjes, Child T did not feel safe visiting Stientjes and his brother (Child A) in Defiance.
158. On October 1, 2018 during the therapeutic session, Van Luven told the children
I had a long conversation today with your guardian ad litem. And her and
I both agree that we really don’t think either of you is going to have a
relationship with the other parent. I don’t think you’re going to have a
relationship with mom, and I don’t think you’re going to have a
relationship with dad.” … I mean really could a judge order you to go live
with mom and you live with dad? With all of this time and history of what’s
gone on, will he? I would sure hope not. [emphasis added].
159. In that same session, Van Luven told Child A and Child T that Child T’s allegations
of domestic violence “is a scheme set up by mom” [Plaintiff] and that domestic violence and abuse
situations “were somehow skewed to you by your mom, and I am just going to call a spade, a
spade. I’m not going to dance around it because that’s what Child A is saying, and that’s how you
[Child T] formulated your opinion.” [emphasis added].
160. In spite of this, Van Luven did not then report to the Court that she would not be
able to reunify Child A and Child T or help Child A and Child T reunify with their respective
parents and Van Luven did not end her therapy.
161. During Van Luven’s sessions, Child T disclosed that Child T was sexually abused
by Stientjes and Child A disclosed that Child A was physically abused by Stientjes. Van Luven
did not report Child A and Child T’s disclosures to DFS, the Court or Pudlowski. Van Luven
continued her therapy with Child A and Child T while ignoring sexually and physically abusive
behavior against Child A and Child T by Stientjes.
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162. During Van Luven’s sessions, Van Luven questioned Child A and Child T about an
adoption their parents attempted several years before they got divorced, the knowledge of which
Van Luven gained solely from the Reid Report. Van Luven demanded that Child T acknowledge
that “not long before your parents separated and filed for divorce, they were trying to adopt a child,
bring another child into the home and there were not these severe allegations until a divorce was
patented.” Any representations made to the adoption agency were made by both parents, not
solely by Plaintiff as Van Luven stated.
163. Van Luven essentially told Child A and Child T that Plaintiff was a liar despite DFS
recorded allegations of abuse by Stientjes and many other healthcare professionals’ corroborating
evidence.
164. On October 10, 2018, Van Luven questioned Child A extensively about his Ottolini
reunification therapy with Plaintiff. She asked Child A what Plaintiff said, what Child A said and
what was discussed in therapy with Ottolini instead of focusing on the relationship between Child
A and Child T. By engaging in this line of questioning, Van Luven put Child A in the position to
breach the confidentiality of Child A’s reunification therapy with Ottolini, at the expense of the
Plaintiff who was in Ottolini’ s care.
165. During an October 31, 2018 therapy session, with Child T, Van Luven asked Child
T whether Child T discussed Van Luven’s therapy with Plaintiff and asked Child T to reveal the
content of these discussions.
166. On November 12, 2018, during Van Luven’s ninth (9th) session, Van Luven used
information from the Reid Report to alienate Child A and Child T from Plaintiff in violation of
August 30, 2017, October 26, 2017, April 5, 2018, and September 18, 2018 Court orders. Van
Luven agreed with Child A that “mom [Plaintiff] is isolating [Child T], and that Plaintiff was
39
telling Child T “this is what happened,” (referring to domestic violence), and that Child T, after
hearing Plaintiff’s stories, “could retell [Plaintiff’s] stories to himself until he believed them.”
167. These comments were inappropriately made in violation of standard of care for
family reunification therapy and in violation of the September 17, 2018 Court order mandating
Van Luven “to reestablish the relationship between the children and the parents.” The comments
also denigrated Child T’s ability to recall the trauma he endured and to tell her about it.
168. During the same session, Van Luven falsely asserted to Child A and Child T that
their mother [Plaintiff] took Child T to Safe Connections to ingrain Child T’s brain with PTSD.
Van Luven stated, “you know, when you go somewhere that just specializes in PTSD, they’re
going to ingrain PTSD in you because that’s what they do. So, that is what they’re going to focus
on.”
169. Van Luven had no basis in fact or in appropriate psychological counseling within
the standard of care to come to that conclusion. Van Luven did not consult with therapists at Safe
Connections in order to evaluate the care given there.
170. On another occasion, Van Luven explained that her job was about “weeding out the
truth.” Van Luven told the Child A and Child T that “the underlying issue here is that you feel like
mom [Plaintiff] is isolating him [Child T] from Child A.” Van Luven ignored that Stientjes
abandoned Child T late at night, in the middle of winter, on a street in Clayton, Missouri and drove
away, credibly had sexually abused Child T and physically threw Child T out of his house as well
in the middle of winter in 2017.
171. Van Luven often used her own family as an example, of her children not getting
along and calling each other “bitch” and “asshole,” thereby normalizing verbally and emotionally
40
abusive language between the siblings. Van Luven also used the word “fuck” during her therapy
session as if it were appropriate.
172. During one therapy session Child A reported, to Van Luven and Child T, that he
had broken into the Plaintiff’s home to take things over the course of two (2) years after Child A
moved out of Plaintiff’s home and into Stientjes’ home. Van Luven, upon hearing of this
disturbing conduct, chose to redirect Child A, rather than challenging Child A’s breaking and
entering and to investigate Child A’s statement that he illegally entered Plaintiff’s home numerous
times over a two (2) year period.
173. Plaintiff reported, to Reid and Van Luven, that Stientjes was on multiple occasions
breaking and entering her home long after the divorce and removing items. But Reid documented
this in his report as Plaintiff’s lies, fraud orchestration, fact manipulation and deception. Even
though Van Luven read the Reid Report, she did not report Child A’s breaking and entering to
Pudlowski, Reid and the Court.
174. Knowing of Child A’s stealing from the Plaintiff’s house, Van Luven chose to
mock Plaintiff’s attempts to report the theft from her house to Reid, in front of Child A and Child
T, during a therapy session. Van Luven suggested to Child A and Child T, that these reports by
Plaintiff to Reid were Plaintiff’s acts of manipulation “to seek negative attention” from Child A
and Child T.
175. Often during therapy sessions with Child A and Child T, Van Luven used examples
from her and her family’s private lives and, on several occasions, stated that Van Luven’s own
children broke laws and rules, thus normalizing this behavior. Van Luven encouraged Child T to
ride in a motor vehicle with Child A in violation of the law, knowing that Child A did not have a
41
valid driver’s license. Van Luven shamed Child T when Child T refused to ride in Child A’s car,
with no adult, before Child A was fully licensed.
176. During these therapy sessions, Van Luven adopted findings in the Reid Report that
were improperly arrived at and aligned with Child A against Child T and Plaintiff in violation of
standard of care for family reunification and in violation of the September 17, 2018 Court Order.
Van Luven validated Child A’s “truths” and Child A’s anger against Plaintiff. Van Luven used her
therapy sessions to alienate Child A and Child T from Plaintiff.
177. Empowered by the Reid Report, Van Luven discussed topics from the Reid Report
with Child A and Child T in violation of the April 5, 2018 Court Order. In doing so, Van Luven
did not reunify the children and their parents, but alienated the Child A and Child T from Plaintiff.
178. Van Luven’s hostile, unprofessional, and abusive therapy further alienated Child A
from Plaintiff and purposely undermined Child T’s therapy at Safe Connections.
179. Child T cried uncontrollably during and after most every therapy session with Van
Luven. Concerned about Child T’s wellbeing, Plaintiff contacted Van Luven who refused to
communicate to Plaintiff, in violation of the Court’s order and Van Luven’s duties as an LCSW.
180. Van Luven regularly cut her sessions short with Child A and Child T and engaged
in inappropriate billing practices by billing Plaintiff extra for the time when Van Luven was not in
therapy with Child A and Child T.
181. Plaintiff contacted Pudlowski several times, asking for Pudlowski’s help with the
hostile, unprofessional and abusive atmosphere facilitated by Van Luven as expressed by Child T.
Pudlowski did not address Plaintiff’s concerns and those expressed by Child T. Instead,
Pudlowski told Plaintiff’s attorney that Child T was lying. Pudlowski again told Plaintiff to enroll
in lifetime therapy recommended by Reid in spite of the many ways Reid violated the standard of
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care and generated his “subjective opinion.” Pudlowski persisted in insisting that Plaintiff pursue
“Reid’s therapy” in spite of the Court denying Pudlowski’s several attempts to have the Court
order that Plaintiff follow Reid’s recommendations as discussed below.
182. Pudlowski never shared with Van Luven, Doctor Williger’s report issued on August
6, 2018 and Doctor Williger’s deposition transcript from September 14, 2018, regarding Reid’s
failures to use the degree of skill and learning ordinarily used under the same or similar
circumstances by the members of Reid’s profession.
183. On at least four (4) occasions, Pudlowski asked the Court to order Plaintiff to cease
her therapy at Safe Connection and order that Plaintiff and Child T see only therapists of
Pudlowski’s choosing. By doing this, Pudlowski overstepped her authority as a GAL and violated
the August 30, 2017 Court Order appointing Pudlowski. Pudlowski repeatedly told Plaintiff that
Plaintiff is “a non-cooperating parent” for failing to abandon Plaintiff’s therapy at Safe
Connections. Pudlowski’s threats were outside the scope of Pudlowski’s Appointment Order to
represent the best interests of Child A and Child T.
184. Despite Pudlowski’s repeated oral motions at each “settlement conference” asking
the Court to order Plaintiff and Child T to cease their therapy at Safe Connections, the Court
ordered Plaintiff and Child T to continue therapy at Safe Connections on September 17, 2018. The
Court never amended its September 17, 2018 order regarding Plaintiff’s and Child T’s therapy at
Safe Connections.
185. The therapy at Safe Connections was beneficial to Plaintiff during her child custody
modification proceedings. It helped Plaintiff cope with emotional pain and provided a safe
environment which was essential for Plaintiff’s healing. The therapy at Safe Connections helped
Plaintiff to deal with anxiety and stress and taught her to regulate her fears, especially those
43
originating from Stientjes’ abuse, Pudlowski’s threats that Plaintiff would Child A and Child T,
and Van Luven’s continuing alienation of Child A and Child T from Plaintiff. Therapy at Safe
Connection helped Plaintiff to stay focused on helping Child A and Child T and reduced Plaintiff’s
feelings of isolation previously imposed by Stientjes. Safe Connections’ support gave Plaintiff
confidence that Plaintiff was not alone and not crazy.
186. At Safe Connections, Plaintiff learned to deal with effects of trauma, shame,
embarrassment, self-blame and low self-esteem through understanding and acknowledgment of the
years of abuse and trauma inflicted on Plaintiff, Child A and Child T, by Stientjes. Plaintiff
learned what a healthy relationship is and what abuse entailed. Plaintiff also learned about
selfcare, coping skills, safety, recreating Plaintiff’s own identity and rebuilding healthy
relationships with family and friends. Pudlowski tried very hard to undermine Plaintiff’s recovery
and healing.
187. On June 7, 2019, therapy with Van Luven came to an abrupt halt after Plaintiff’s
counsel told Pudlowski that Plaintiff could no longer pay for Van Luven’s therapy. Van Luven
then immediately ended her work with Child A and Child T.
188. While Plaintiff was trying to recover from Van Luven’s Child Alienation Therapy,
Van Luven, Stientjes, Reid and Pudlowski continued communicating among themselves and
totally ignored Plaintiff. On July 1, 2019, on advice from Pudlowski, Stientjes demanded that
Plaintiff undergo a second (2nd) evaluation by Reid. This second (2nd) evaluation of Plaintiff by
Reid never occurred.
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COUNT I
ACTION IN BREACH OF STANDARD OF CARE AGAINST
DEFENDANTS REID AND JAMES D. REID PH.D., LLC
189. Plaintiff re-states and re-alleges each and every allegation stated above as if they are
fully set forth herein.
190. Reid was appointed by the Court in case 16SL-DR04088-01 on October 26, 2017
and owed Plaintiff the duty of acting within the standard of care for a forensic psychological
evaluation. Devitre v. Orthopedic Center of St. Louis, LLC, 349 S.W. 3d 327 (Mo. en Banc 2011).
191. Reid also owed Plaintiff the duty of care as established by the Court’s Order
appointing Reid and by the SOU. Each required that Reid be objective, act as a forensic
psychologist, conduct a psychological evaluation and be impartial.
192. Reid departed from the established standards of his profession when conducting a
forensic psychological evaluation by failing to use the required degree of skill and learning
ordinarily used by psychologists involved in forensic evaluations of child custody litigants and
their children under the same or similar circumstances by the members of Reid’s profession in one
or more of the following ways:
a. by violating the standard of care as identified by Doctor Williger and stated in
paragraph 121 (a-m);
b. by failing to use standard methodology used by other family court forensic
psychologists providing services under similar circumstances as Reid in data
gathering, data analysis, data testing, behavioral observation, interviewing, and
reviewing all relevant records;
c. by tampering with audio and video recordings and by destroying evidence;
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d. by failing to use MMPI assessments specifically designed to account for Plaintiff’s
cultural background of being born and raised in the former Soviet Union;
e. by failing to use MMPI assessments specifically designed for family custody
litigants with children;
f. by failing to account for or report the objective testing that would have given the
Court notice that Stientjes’ uncontrolled emotions, belligerence, lack of empathy,
and disregard for the law, are consistent with a personality disorder;
g. by failing and refusing to investigate and account for a pattern of Stientjes’ sexual
abuse of Child T that was documented by the Olivette Police Department and the
Children’s Justice Center;
h. by failing and refusing to investigate and account for Child A’s disability and
diagnoses of an autistic spectrum disorder, Attention Deficit and Hypoactivity
Disorder, PICA, and Oppositional Defiant Disorder and seven (7) disciplinary
reports from Child A’s school by the time of Reid’s evaluation (one being Child A
stealing his teacher’s identity; creating an Instagram account with his teacher’s
name, making posts with his teacher’s name and sending these posts to other
students in Child A’s school, to which Reid said “many teenagers do that”);
i. by failing and refusing to investigate Stientjes’ domestic violence, Stientjes’ mental
and physical abuse and Stientjes’ alienation of Child A and Child T from Plaintiff;
j. by failing to identify domestic abuse, attribute domestic abuse and account for
domestic abuse as was required by the guidelines established by the Association of
Family and Conciliation Courts, and their Standards of Practice for child Custody
Evaluations;
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k. by engaging in excessive and extortive billing practices in contravention of RSMo.
191.227;
l. by failing and refusing to investigate and to account for the IRS disciplinary
proceedings in which the IRS sought to suspend Stientjes’ ability to represent
taxpayers before the IRS as a result of Stientjes’ “profanity laced threat” to an IRS
attorney;
m. by failing and refusing to investigate and to account for the IRS placing Stientjes on
three (3) year probation only after Stientjes blatantly lied to the IRS that Stientjes
had completed anger management therapy and that Stientjes was no longer involved
in certain prohibited transactions;
n. by failing and refusing to investigate and to account for Stientjes’ underreporting of
Plaintiff’s income, for five (5) years during Plaintiff’s marriage to Stientjes, by
Stientjes reporting Plaintiff’s income as his own, resulting in Plaintiff’s loss of
social security earnings, pension contributions, and materially damaging Plaintiff’s
credit;
o. by failing and refusing to investigate and to account for Stientjes relocating Child A
to Defiance, Missouri in violation of the Court ordered Parenting Plan and the
relocation notice required by Missouri statute.
p. by failing and refusing to investigate and to account for Stientjes being involved in
a real estate transaction, that defrauded a Saint Louis bank of over two hundred
thousand dollars ($200,000.00); and
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q. by failing and refusing to investigate and to account for a well-documented pattern
of domestic violence abuse by Stientjes contained in seven DFS investigations, an
Olivette Police Report, medical and therapy records.
193. As a direct and proximate result of Reid’s violations of the standard of care,
Plaintiff suffered the following damages:
a. Plaintiff suffered the alienation of Child A and Child T from Plaintiff;
b. Plaintiff, Child A and Child T, did not receive the Court ordered family
reunification counseling aimed “to reestablish the relationships between the
children and the parents” and “to reunify the family and to improve relationships
within the family.”
c. Child A’s medical conditions and disabilities were ignored while Child A’s
unhealthy anger towards Plaintiff was validated, fueled, and empowered;
d. Child A was further distanced from Child T;
e. Child T suffered severe depression for which Plaintiff was required to provide
treatment at Plaintiff’s expense;
f. Plaintiff had to expend much energy and effort to help Child T receive treatment to
recover from depression that Plaintiff otherwise would not have expended;
g. Plaintiff, Child A and Child T required past and will continue to require future
therapies and Plaintiff will be required to pay for those therapies; and
h. Plaintiff is entitled to recover fees Reid charged and collected from Plaintiff for the
incompetent services provided in breach of standard of care.
194. Plaintiff is entitled to recover against Reid all damages allowed by law, without
limitation, for all past, present, and future medical and therapeutic expenses, for litigating related
48
fees and expenses, and for loss of time and family relationships with Child A and Child T. All
categories of Plaintiff’s damages stated above are continuing, ongoing and will continue into the
future.
195. Plaintiff is entitled to recover pre-judgment interest, attorneys’ fees, and expenses,
as determined by this Court, and for such other and further relief as this Court deems just and
proper under the circumstances.
WHEREFORE, Plaintiff prays for judgment on Count I of her Petition against Reid in an
amount that is fair and reasonable in excess of twenty five thousand dollars ($25,000.00), for her
costs, attorney fees and for such other and proper relief the Court deems just and proper under the
circumstances herein.
COUNT II
BREACH OF CONTRACT AGAINST
DEFENDANTS REID AND JAMES D. REID PH.D., LLC
197. Reid was appointed by the Court in case 16SL-DR04088-01 on October 26, 2017 to
“exercise his independent objective judgement in conducting the evaluation.” (See Exhibit 2).
198. Relying on the October 26, 2017 Court Order, Plaintiff entered into the SOU with
Reid, the essential terms of which are described in paragraphs 84-85 above and a copy of which is
attached as Exhibit 2.
199. Plaintiff paid Reid approximately thirty thousand ($30,000.00) dollars for his
services in accordance with the terms of the SOU.
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200. Reid materially breached his obligations under the SOU by failing to provide
Plaintiff with the services Plaintiff bargained for with Reid and which Reid obligated himself to
meet by his agreement to the SOU.
201. Under the terms of the SOU, Reid had an obligation to act in good faith, to deal
fairly and honestly, to act reasonably, to comply with the Court Order appointing him, to act
objectively and to act within the standard of care of a forensic psychologist toward Plaintiff.
202. Plaintiff fully performed her obligations to Reid and did not contribute to Reid’s
breaches in any way. In spite of Plaintiff’s compliance with the terms of the SOU, Reid breached
the contract’s terms in numerous ways as stated in paragraphs above.
203. Reid charged and collected from Plaintiff fees for the deeply flawed services
provided in the breach of the contract between Reid and Plaintiff. The fees Reid charged were
unreasonable and violated the October 26, 2017 Court Order and the SOU. They are excessive and
are in violation of the Missouri Rules of Conduct governing psychologists, including Rule
11(A)(3) that prohibits psychologists from “exploit[ing] a client or payor by charging a fee that is
excessive for the services performed;” Rule 11(B)(4) which prohibits psychologists from “bill[ing]
for services that are not rendered;” Rule 13(B) which prohibits “fraud, misrepresentation or
deception in billing clients or third party payors.”
204. As a direct and proximate result of Reid’s conduct in breach of his contractual
obligations to Plaintiff, Plaintiff suffered damages, which include, but not limited to: (a) Plaintiff
paid Reid in excess of twenty five thousand dollars ($25,000.00); (b) Plaintiff endured three (3)
years of painful and costly litigation contesting Reid’s Report; (c) Plaintiff suffered Child A and
Child T’s alienation from her; (d) Plaintiff suffered emotional distress and pain; (e) Plaintiff did
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not receive reunification therapy ordered by the Court; and (f) Child A and Child T did not receive
the Court ordered therapy to nurture their relationship with Plaintiff.
205. Reid’s breach of the SOU has caused Plaintiff to suffer damages and will continue
to cause her damages in excess of twenty-five thousand dollars ($25,000.00) and which will be
established by a jury.
WHEREFORE, Plaintiff prays for a judgment in her favor on Count II of her Petition
against Reid in an amount to be determined at trial, to compensate her for her above described
damages, for her costs of bringing this action, attorney fees and for such other and further relief
that the Court deems just and proper under the circumstances herein.
COUNT III
BREACH OF FIDUCIARY DUTY AGAINST
DEFENDANT PUDLOWSKI
206. Plaintiff re-states and re-alleges each and every allegation stated above as if they
are fully set forth herein.
207. Pudlowski was appointed by the Court in case 16SL-DR04088-01 to serve as a
GAL for Child A and Child T on August 30, 2017. Pursuant to the Appointment Order and
Standard 7 of the Missouri Supreme Court Standards governing the conduct of GALs, Pudlowski
was required “to adhere to applicable statutes, rules and regulations relating to receipt and
redisclosure of privileged information received as GAL.”
208. Pudlowski, by filing her entry of appearance, acknowledged her obligation to
comply with the Missouri Supreme Court Standards for GALs and Court Orders in Plaintiff’s child
custody proceedings.
209. Pudlowski’s GAL Appointment Order required Pudlowski to comply with the
Missouri Rules of Professional Responsibility (MRPR), namely, Rule 4-3.4 (c) which prohibited
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Pudlowski from “knowingly disobey[ing] an obligation under the rules of a tribunal, except for an
open refusal based on an assertion that no valid obligation exists.”
210. Pudlowski’s GAL Appointment Order required Pudlowski to comply with MRPR
Rule 4-8.3(a), requiring her to self-report her conduct which violated MRPR Rules 4-3.4(c) and 4-
8.4 (to inform the appropriate professional authority, i.e. the Court in case 16SL-DR-4088-01 and
the Disciplinary Committee of the Bar of her violations of the Court Orders).
211. Pudlowski’s GAL Appointment Order required Pudlowski to comply with MRPR
Rule 4-8.4(a) which prohibited her from “violat[ing] or attempt[ing] to violate the Rules of
Professional Conduct, knowingly assist[ing] or induc[ing] another to do so, or do so through the
acts of another;” (c) “engag[ing] in conduct involving dishonesty, fraud, deceit, or
misrepresentation;” (d) “engag[ing] in conduct that is prejudicial to the administration of justice;”
and (g) “manifest[ing] by words or conduct, … bias or prejudice.”
212. Under four (4) Court Orders, Pudlowski was obligated not to release Plaintiff’s
confidential information, Plaintiff’s private medical records and all Plaintiff’s information
contained in the Reid Report, including Reid’s opinions and recommendations, to anyone except to
the attorneys representing Plaintiff and Stientjes.
213. Pudlowski knowingly and intentionally breached her fiduciary duty owed to
Plaintiff when Pudlowski released the Reid Report to Van Luven and coerced Plaintiff to agree to
release it to Ottolini in violation of four (4) Court Orders.
214. Pudlowski’s unlawful release of the Reid Report was highly prejudicial to Plaintiff.
215. Having violated four (4) Court Orders, Pudlowski did not inform the Court of her
malfeasance.
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216. As a direct and proximate result of Pudlowski’s breaches of her fiduciary duty to
Plaintiff, Plaintiff suffered the following damages:
b. Plaintiff, Child A and Child T did not receive the Court ordered family reunification
counseling aimed “to reestablish the relationships between the children and the
parents” and “to reunify the family and to improve relationships within the family,”;
c. Child A’s medical conditions were ignored while Child A’s unhealthy anger
towards Plaintiff was validated, fueled, and empowered;
d. Child T suffered severe depression requiring Plaintiff to provide treatment for Child
T at Plaintiff’s expense;
e. Plaintiff had to expend much energy and effort to help Child T receive treatment to
f. Plaintiff, Child A and Child T required past and will continue to require future
therapies and Plaintiff will be required to pay for those therapies; and
g. Plaintiff is entitled to recover fees Pudlowski charged and collected from Plaintiff
for the services Pudlowski provided in the breach of Pudlowski’s fiduciary duty to
Plaintiff.
217. Plaintiff is entitled to recover against Pudlowski all damages allowed by law,
without limitation, for all past, present, and future medical and therapeutic expenses, for litigation
related fees and expenses, and loss of time and family relationships with Child A and Child T. All
categories of Plaintiff’s damages are continuing, ongoing and will continue into the future.
53
WHEREFORE, Plaintiff prays for judgment on Count III of her Petition against Pudlowski
in an amount that is fair and reasonable in excess of twenty-five thousand dollars ($25,000.00) for
her costs, interest, attorney fees and for any other and further relief the Court deems just and
proper under the circumstances herein.
COUNT IV
ACTION FOR BREACH OF STANDARD OF CARE AGAINST
DEFENDANTS FITZGIBBONS AND VAN LUVEN
219. Plaintiff re-states and re-alleges each and every allegation stated above as if they
are fully set forth herein.
220. Van Luven was Court appointed to serve as a Court Appointed Therapist (CAT) of
Child A, Child T and their parents on September 17, 2018.
221. Pursuant to this Court Order, Van Luven was required to use her education, training
and experience to reunite Child A and Child T and “to reestablish the relationships between the
children and the parents” and “to reunify the family and to improve relationships within the
family.” Van Luven departed from the established standards of conduct of her profession by
failing to use the required degree of skill and learning ordinarily used by an LCSW involved as a
CAT of child custody litigants and their children, under the same or similar circumstances by the
members of Van Luven’s profession in one or more of the following ways:
a. by Van Luven failing to follow the Court Orders to promote successful
psychological treatment to reunify the children and their parents;
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b. by Van Luven failing to promote family unity and instead engaged in causing
alienation of Child A and Child T from Plaintiff;
c. by Van Luven failing to assess various treatment hypotheses by critically examining
well documented domestic violence by Stientjes, Child Abuse by Stientjes, high
conflict dynamics, including risks to the children from exposure to parental conflict,
and Child A and Child T alienation from Plaintiff;
d. by Van Luven failing to limit her opinions within the confines of her therapeutic
role and objective data;
e. by Van Luven failing to seek Plaintiff’s perspective of the treatment process;
f. by Van Luven failing to maintain neutrality towards both parents knowing that
inappropriate treatment would escalate family conflict and cause significant damage
to family relationships;
g. by Van Luven failing to provide consultations intended to reunify Child A and
Child T with Plaintiff, nor did Van Luven inform the Court that her treatment
failed;
h. by Van Luven failing to consider Child A’s special needs and prior diagnoses of
autistic spectrum disorder, ADHD, ODD, and PICA and Child A’s school
disciplinary record;
i. by Van Luven validating, empowering, fueling, and encouraging Child A’s anger,
hatred, and alienation towards Plaintiff and by ignoring both Child A and Child T’s
medical conditions and welfare;
j. by Van Luven failing to communicate with Plaintiff after learning of the contents of
the Reid Report;
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k. by Van Luven failing to withdraw from the case when Van Luven concluded that
she was unable to reunify Child A and Child T and help them to reunify with their
parents;
l. by Van Luven failing and refusing to file a report with the DFS as required by
Missouri law, when statements of sexual abuse and physical abuse are disclosed;
and
m. by Van Luven engaging in the inappropriate and excessive billing practices.
222. As a direct and proximate result of Van Luven’s violations of the standard of care,
Plaintiff suffered the following damages:
g. Plaintiff suffered the alienation of Child A and Child T from Plaintiff;
h. Plaintiff, Child A and Child T, did not receive the Court ordered family
reunification counseling aimed “to reestablish the relationships between the
children and the parents” and “to reunify the family and to improve
relationships within the family”;
i. Child A’s medical conditions were ignored while Child A’s unhealthy anger
towards Plaintiff was validated, fueled, and empowered causing Plaintiff’s
anguish and emotional suffering;
j. Child A was further distanced from Child T;
k. Child T suffered severe symptoms of depression for which Plaintiff was
required to provide him with treatment at Plaintiff’s expense;
l. Plaintiff had to expend much energy and effort to help Child T receive treatment
to recover from depression that Plaintiff otherwise would not have expended;
m. Plaintiff has endured painful and stressful litigation;
56
n. Plaintiff, Child A and Child T required past and will continue to require future
therapies and Plaintiff will be required to pay for those therapies;
o. Child A is not receiving and may never receive the therapies necessary to cope
with his mental illness and disability disorders;
p. Child T is not being treated and may never be treated for depression due to Van
Luven’s failure to develop a trusting and safe place to explore his experience;
and
q. Plaintiff is entitled to recover fees Van Luven charged and collected from
Plaintiff for the incompetent and injurious services Van Luven provided in the
breach of standard of care.
223. Plaintiff is entitled to recover against Van Luven all damages allowed by law,
without limitation, for all past, present, and future medical and therapeutic expenses, for litigation
related fees and expenses, and for loss of time and family relationships with Child A and Child T.
Plaintiff’s suffering and damages are continual and ongoing and will continue into the future.
WHEREFORE, Plaintiff prays for judgment on Count IV of her Petition against Van
Luven in an amount that is fair and reasonable in excess of twenty-five thousand dollars
($25,000.00), for costs, attorney fees and for any other and further relief the Court deems just and
proper under the circumstances herein.
57
COUNT V
BREACHES OF FIDUCIARY DUTIES AGAINST
DEFENDANTS FITZGIBBONS & VAN LUVEN
226. By accepting the Court appointment as a therapist on September 17, 2018, Van
Luven accepted her fiduciary duties and acknowledged that she would know and follow the Court
Orders in Plaintiff’s child custody proceedings when providing therapy to reunite Child A and
Child T, “to reestablish the relationships between the children and the parents” and “to reunify the
family and to improve relationships within the family.”
227. Van Luven’s CAT Appointment Order required her to comply with 20 CSR 2263-
3.100 “to inform clients, at the onset of the professional relationship, of the limits of confidentiality,”
“to keep confidential his/her therapy relationships with clients including information obtained from
this relationship with clients with the following exceptions (A) “when the client gives written
consent;” (B) “when the client constitutes a danger to him/herself or to others.”
228. The Association of Family and Conciliation Courts (“AFCC”) Guidelines for
Court-Involved Therapy, Guideline 7.1, required Van Luven to be aware of section 337.636 of the
Missouri Revised Statute and HIPPA laws and regulations pertaining to client/patient
confidentiality and privilege and to be aware that ethical, clinical and legal issues related to
confidentiality/privilege may differ depending on whether a parent, child or family is in treatment.
AFCC Guideline 7.2 of the states that a CAT has a duty to resist disclosure of the information and
to determine whether disclosure of the information risks the welfare of the child. AFCC Guideline
7.4 states that if there is a dispute regarding privacy, confidentiality and privilege, a CAT should
seek clarification from the Court prior to commencing her services.
58
229. Van Luven accepted the trust and fiduciary duties owed Plaintiff conferred on Van
Luven by the Court Orders, Missouri law, and HIPPA regulations.
230. Van Luven knowingly and intentionally breached trust and fiduciary duties owed
Plaintiff in one or more of the following ways:
a. by failing to inform Plaintiff, Child A and Child T of the limits of confidentiality
and seeking agreement among the parties concerning each individual’s right to
confidentiality;
b. by failing to seek Plaintiff’s informed consent to accept the Reid Report from
Pudlowski and to disclose it to Child A and Child T; and
c. by failing to comply with four (4) Court Orders of August 30, 2017, October 26,
2017, April 5, 2018, and September 17, 2018, prohibiting disclosure of the Reid
Report to Van Luven and prohibiting Van Luven disclosing the contents of the Reid
Report to Child A and Child T.
231. Plaintiff trusted Van Luven by virtue of her CAT appointment and Van Luven’s
credentials as an LCSW.
232. As a direct and proximate result of Van Luven’s breaches of her fiduciary duties to
Plaintiff, Plaintiff suffered the following damages:
b. Plaintiff, Child A and Child T, did not receive the Court ordered family reunification
counseling aimed “to reestablish the relationships between the children and the
parents” and “to reunify the family and to improve relationships within the family;”
59
c. Child A’s medical conditions were ignored while Child A’s unhealthy anger
towards Plaintiff was validated, fueled, and empowered causing Plaintiff much
suffering;
d. Child T suffered severe depression for which Plaintiff was required to provide him
with treatment at Plaintiff’s expense;
e. Plaintiff had to expend much energy and effort to help Child T receive treatment to
f. Plaintiff, Child A and Child T endured painful and stressful litigation;
g. Plaintiff, Child A and Child T required past and will continue to require future
therapies and Plaintiff will be required to pay for those therapies;
h. Child A is not receiving and may never receive required therapies to cope with his
mental illness and disability disorders causing Plaintiff much anguish; and
i. Child T is not being treated and may not be treated for depression causing Plaintiff
much anguish.
233. Plaintiff is entitled to recover fees Van Luven charged and collected from Plaintiff
for the incompetent and injurious services Van Luven provided in the breach of fiduciary duties in
violation of four (4) Court Orders.
234. Plaintiff is entitled to recover against Van Luven all damages allowed by law,
without limitation, for all past, present, and future medical and therapeutic expenses, for litigating
related fees and expenses, and for loss of time and family relationships with Child A and Child T
and for Plaintiff’s emotional suffering. Plaintiff’s damages are ongoing and will continue into the
future.
60
235. Plaintiff is entitled to a recovery of pre-judgment interest, attorneys’ fees, and
expenses, as determined by this Court, and for such other and further relief as this Court deems just
and proper under the circumstances.
WHEREFORE, Plaintiff prays for judgment on Count V of her Petition against Van Luven
in an amount that is fair and reasonable in excess of twenty-five thousand dollars ($25,000.00), for
costs, attorney fees and for any other and further relief the Court deems just and proper under the
circumstances herein.
COUNT VI
VIOLATION OF MISSOURI MERCHANDISING PRACTICES ACT AGAINST
ALL DEFENDANTS
237. Plaintiff is “a person” as defined in the Missouri Merchandising Practices Act at
Mo. Rev. Stat. § 407.010 (5).
238. Reid and Van Luven are individuals and businesses that sell psychological and
therapeutic family services.
239. Reid holds himself out to the public and to Saint Louis County Courts, as an
independent, impartial, and well-experienced expert conducting forensic psychological evaluations
for family courts in the Saint Louis Metropolitan Area.
240. Van Luven holds herself out to the public and to Saint Louis County Court as a
Missouri LCSW experienced in family reunification counseling with significant expertise in
reunifying children, siblings and family members involved in divorce and child custody litigation
proceedings.
241. Pudlowski is an individual who sells certified, court appointed GAL services.
61
242. Pudlowski holds herself out to the public and to Saint Louis County Court as a
certified court appointed GAL, family law mediator, and parent coordinator.
243. The services and events complained of in this Petition constitute, “trade or
commerce” as defined in the Missouri Merchandising Practices Act at Mo. Rev. Stat. § 407.010
(7). Trade and practice encompass psychological, therapeutic, and legal services. Mo. Rev. Stat. §
407.010 (4) and (7).
244. The Missouri Merchandising Practices Act prohibits unfair practices, use or
employment of false promises, misrepresentation, or omission in the conduct of trade or
commerce, including provision of services as set forth in Mo. Rev. Stat. § 407.020.1.
245. Plaintiff purchased services that Reid, Pudlowski and Van Luven offered.
246. Plaintiff purchased their services for personal and family use.
247. Plaintiff suffered significant and ascertainable losses as a result of purchasing Reid,
Pudlowski and Van Luven’s services.
248. The significant and ascertainable losses were the result of the unfair and deceptive
practices by Reid, Pudlowski and Van Luven as stated above in this petition.
249. Reid’s conduct violated the Missouri Merchandising Practices Act on numerous
occasions as previously stated in paragraphs above.
250. Pudlowski’s conduct violated the Missouri Merchandising Practices Act on
numerous occasions as previously stated in paragraphs above.
251. Van Luven’s conduct violated the Missouri Merchandising Practices Act on
numerous occasions as previously stated in paragraphs above.
252. As a direct and proximate result of Reid, Pudlowski and Van Luven’s violations of
the Missouri Merchandising Practices Act Mo. Rev. Stat. § 407.025, Plaintiff is entitled to a
62
recovery of her actual damages in an amount to be proven at trial, an award of punitive damages,
an award of reasonable attorney’s fees, injunctive relief prohibiting Defendants unfair and
deceptive conduct prospectively, and any other penalties or awards that may be appropriate under
applicable law.
WHEREFORE, Plaintiff prays for judgment on Count VI of her Petition against Reid,
Pudlowski and Van Luven for a) actual compensatory damages in an amount to be determined at
trial; b) an award of punitive damages in an amount to be determined at trial; c) injunctive relief
prohibiting Defendants from continuing to commit the deceptive and unfair acts alleged herein; d)
an award of reasonable attorney’s fees and costs; and e) such further and other relief the Court
deems reasonable and just.
JURY DEMAND
Plaintiff requests trial by jury of all claims that can be so tried.
/s/ Laurence D. Mass

Laurence D. Mass, Esq. Mo. Bar # 30977
230 S. Bemiston Avenue, Suite 1200
Saint Louis, Missouri 63105
Phone: (314) 862-3333 ext. 20
Fax: (314) 862-0605
e-mail: laurencedmass@att.net
/s/ Timothy W. Roldan

The Law Office of Timothy W. Roldan, Mo. Bar # 49842
Timothy W. Roldan, MSW, LCSW, Esq.
7711 Bonhomme, Suite 815
Clayton, Missouri 63105
(Cell) (314) 996-9169
e-mail: TWRoldanLLC@live.com
63
Electronically Filed - St Louis County - August
September
25, 2017
10, 2020
- 09:31
- 12:11
AM AM
EXHIBIT 1
Electronically Filed - St Louis County - August
September
25, 2017
10, 2020
- 09:31
- 12:11
AM AM
Division 99
Division 35
June 10,30,
August 2017
2015
Judge
Judge
James D. Reid, Ph.D., LLC
Licensed Psychologist
Psychodiagnostic Assessment, Parenting Coordination, Mediation & Psychotherapy
Psychological Service Center (314) 409-1864

7 North Jackson
Suite 100
Clayton, Missouri 63105 dr.jamesdreid@gmail.com
November 7, 2017
Evita Tolu, Petitioner, vs. Robert Stientjes, Respondent

In the Circuit Court of St. Louis County
Cause No. 16SL-DR04088-1
RE: PSYCHOLOGICAL EVALUATION ORDER
Client: UNLESS THE ORDER FROM THE COURT EXPLICITLY STATES

OTHERWISE, THE COURT IS TO BE CONSIDERED THE CLIENT OF DR. REID IN
THIS CONTRACT FOR HIS INDEPENDENT PROFESSIONAL JUDGEMENTS.
The Court Order states: “James. D. Reid, Ph.D., (“Evaluator”) is appointed to conduct a
psychological evaluation of Petitioner and Respondent…The purpose of this evaluation
shall be to evaluate the psychological status of Petitioner and Respondent, and their
minor children, and to assess any allegations or issues regarding their current mental
health and the parenting ability of each parent specific to this case bearing on the best
interests of the children. The Evaluator shall offer opinions and recommendations
regarding this case.”
General Information:
I have been appointed by the Court to conduct an impartial evaluation of comparative
custodial fitness. My purpose in conducting this evaluation is to gather information that
will enable me to formulate an opinion concerning parental strengths and weakness and
what custody/visitation arrangement is most likely to be in the best interests of your
child(ren). Though the manner in which my fees will be paid has been determined either
by the Court or through negotiations among the parties and their attorneys, and though
my fees are not paid by the Court, the work that I will be doing will be done for the
Court. Regardless of the source from whom impartial evaluators receive remuneration,
impartial evaluators are expected to operate as though they were employed by the Court.
It is particularly important that this position be understood when fees are being paid only
by one of the two parties. The fee-paying party cannot simply call a halt to the evaluation.
The authority to instruct an evaluator to perform no further services rests with the Court,
not with the party who bears the financial responsibility for payment of the evaluator’s
fees (nor with that party’s attorney).
I do not presume that those whom I am evaluating are being untruthful; however, neither
do I presume that they are being truthful. Forensic psychologists are expected to secure
EXHIBIT 2
Statement of Understanding
Tolu v. Stientjes
verification of assertions made by those whom they are evaluating. Your cooperation will
be expected as verification of assertions made by you is sought.
Upon completion of my evaluation, a report will be prepared and sent to the Court.
Unless otherwise instructed by the Court, copies will be sent to the attorneys for both
litigants and to the attorney(s) representing the child(ren). When individuals are
representing themselves, I will follow direction from the Court concerning whether or not
to provide a copy of the report. Your signature on the last page of this document will
authorize me to release information to the attorneys and to the Court at any point in the
evaluative process, to release to them my final advisory report, and to release my file to
anyone who is authorized by law to review it.
Privilege, Confidentiality, and Privacy:

Principles of confidentiality and privilege do not apply within the context of an
assessment such as the one being conducted. Information provided by you, regardless of
the form in which it has been provided (your statements, tape recordings, diaries,
correspondence, photographs, etc.) may be shared with others involved in the evaluation
(including, where necessary and appropriate, children and collateral sources). By
presenting information to others, verification of information provided by you can be
sought and the other party can be afforded the opportunity to respond to allegations that
may have been made. Statements made by children may have to be cited in a report and it
is, therefore, important that you not mislead your child(ren). Do not tell a child that what
is said is confidential. It is not. Information concerning your payments (amounts, source
of payments, form of payments) is also not confidential. Office staff must check my
telephone messages, read my mail, and type my correspondence and reports. Those who
work for me receive instruction in matters relating to confidentiality. The need may arise
for me to discuss the evaluation with other professionals and/or provide a copy of the
final report and pertinent supporting documents to colleagues for their review and
comments. In such cases, all names and identifying information will be changed.
Fees/Deposit:
The fee for all time and services by Dr. Reid is $250.00 per hour for consultation-related
services provided in my office, and $350.00 per hour for legal proceedings, including
time reserved to prepare for legal proceedings, provide depositions and court testimony.
Times for depositions and court testimony are billed in ½ day (1 to 4 hours or $1400.00)
or whole day (4 to 8 hours or $2800.00) increments and must be paid when I am asked to
reserve time on my calendar for trial or deposition. I will not schedule trial time or
deposition time without advance payment for the time being reserved. If at the time a trial
or deposition is scheduled, the deposit is exhausted, or nearly exhausted, an additional
deposit will be required to cover the time it will take me to prepare for deposition or trial.
There is a minimum deposit of $6,000.00. The order of the Court states that each parent
is responsible for 50%. Appointments with Dr. Reid will be automatically canceled
without notice if the deposit is not paid in full at least 5 business days in advance of the
first appointment or scheduled service.
2
Tolu v. Stientjes
The deposit is a credit balance against which fees shall be charged. Should the
consultation or examination be canceled or not completed for any reason at any time by
any party or attorney other than Dr. Reid, a minimum portion of the deposit will be non-
refundable, to equal 2 hours of time for review of the materials. Dr. Reid shall return any
unused remaining refundable portion of the deposit within ten business days from the
time that he is notified by the attorney that Dr. Reid’s services will no longer be required
in the matter and that information is verified with the attorneys in the case.
The actual final cost of forensic services varies tremendously depending on the amount of
time spent by Dr. Reid and the amount of contact with the parties and the attorneys, the
number or other persons to be included, the amount of information to be read, and the
degree of complexity of the matter. Dr. Reid’s fees may substantially exceed the initial
deposit, in which case counsel should anticipate that additional deposits shall be required.
Deposits and fees shall be paid promptly when requested by Dr. Reid. All services will be
suspended if deposits or fees are not paid when requested. Testimony, reports, and
opinions will not be written or released unless account balances are current and deposits
have been paid. Should a check be returned by the bank for any reason whatsoever, a
$25.00 return check fee will be added.
My services as an evaluator commence with my acceptance of the assignment to conduct

an evaluation. Though I do not actively seek information prior to our first evaluative
session, information may come to me in the form of statements made in telephone
interactions, pleadings, etc. Even information not actively sought by me will be
considered by me in the formulation of my opinions (since, in my view, ignoring
unsought information is not a viable option). Additionally, in most cases, some time will
have been expended by me prior to your receipt of this document (for example: phone
time with the Court, Guardian ad Litem, and/or attorneys representing one or both
parties). For these reasons, fees are charged retroactively; that is, from the time of my
notification by the Court of my appointment to conduct this evaluation. Fees for service
shall include, but not be limited to, charges for interviews, testing, test scoring, test
interpretation, telephone and e-mail contacts with Dr. Reid, professional consultations,
interviews, broken and canceled appointments, reviewing documents, preparing
affidavits, reserving time for testimony, and photocopying.
If, in my judgment, it is advisable that I consult with other mental health professionals,
attorneys, or other professionals, time expended by me in such consultations will be
billed for.
The record-keeping requirements of forensic work make it necessary to log each

telephone and e-mail message and make a record of even the briefest contact. For this
reason, there will be a minimum fee of $20 (5 minutes @ $250/hour) charged for any
contact.
3
Tolu v. Stientjes
Once an evaluation has been concluded, fees paid may be reapportioned through
negotiations among the parties and their attorneys or by Court Order; however, while the
evaluation is in progress, fees cannot be apportioned based upon what was done for
whom. All work relating to the assessment (obtaining and reviewing documents,
contacting others for information, etc.) is done in order to obtain as much relevant
information as possible and cannot be viewed as work done for one party or for the other.
Similarly, fees cannot be apportioned in a manner that involves assigning financial
responsibility for the fees associated with certain services to one party and responsibility
for fees associated with other services to the other party.
There may be times when an individual being evaluated will be required to pay fees for
time expended by me in obtaining and reviewing information that the individual would
have preferred that I not obtain or review. Similarly, there may be times when the
financially responsible party (parties) will be required to pay fees in connection with the
evaluation of a third party whom the financially responsible party (parties) would have
preferred that I not evaluate.
If it should become necessary for me to report allegations of abuse/neglect to Child

Protective Services (CPS), the financially responsible party (parties) will be billed for any
time expended in filing the report, being interviewed by CPS, etc. This may mean that a
financially responsible party will have to pay for time expended in reporting him/her to
CPS.
There may be times when the actions of one party will make it necessary for me to make
phone calls and/or write letters. In calculating fees for my services, no distinction is made
between time expended in administrative matters and time expended in providing
psychological services. Fees for time expended in administrative matters are apportioned
as are all other fees. In summary, fees are charged for time expended in any/all
professional activities associated with the evaluative process or arising from the
evaluative process. This includes time expended in addressing fee-related matters.
It is to your advantage to organize any material that you submit for my consideration.
You are paying for my time and more time is required to review material if it has been
poorly organized. Any items submitted to me should be clearly identified with your
name. This is particularly important in the case of photographs, audio tapes, diary pages,
and notes.
The performance of evaluation-related services by me does not cease with the issuance of
my report. Fees for all post-evaluation services (correspondence, phone time, etc.) are the
responsibility of the party requesting the services, unless other arrangements have been
made in advance or the Court has ordered that responsibility for these fees be apportioned
in some other manner.
If there is a trial or if an evaluator is called to be deposed, an expert cannot be compelled

to offer opinions without remuneration. If one wishes an expert to make a Court
4
Tolu v. Stientjes
appearance or appear at a deposition, one must pay the expert’s fees for time expended,
including reasonable fees for time expended in preparation. I must, therefore, require that
you agree that if my presence is requested for any reason, the fees specified will be paid
by the party requesting my presence, unless other arrangements have been made in
advance or the Court has ordered that responsibility for these fees be apportioned in some
other manner. Additionally, the scheduling of my testimony will be done in consultation
with me and with an appropriate recognition of possible conflicting personal or
professional commitments. In the unlikely event that an appearance by me is requested by
the Court or by the Guardian, my fees will be paid by the party (parties) responsible for
the other costs associated with my evaluation and in the same proportions.
If this portion of the Statement of Understanding raises any questions concerning your
possible financial obligations, please bring your questions to my attention and to the
attention of your attorney.
Third Party Payment:

The acceptance by Dr. Reid of direct payment from any third party shall be construed
only as a payment having been made by the third party on the behalf of the financially
responsible party and will be credited to the financially responsible party’s account. This
will not be construed as an indication that the third party is or has become the financially
responsible party nor that the party has become a client of Dr. Reid.
Insurance Company Payments:

The use of health insurance by a party is not a substitute for the financial obligations
described herein. Most physical health and mental health insurance is intended for the
provision of treatment and does not usually cover forensic services. Misrepresentation of
services by a provider to an insurance company in the attempt to obtain coverage for an
otherwise uncovered service may constitute a felony. All of Dr. Reid’s bills will clearly
state that a forensic service has been provided. Should an insurance company,
nevertheless, chose to provide coverage for a forensic service, the acceptance by Dr. Reid
of such payment shall be construed only as payment having been made by a third party
on the behalf of the financially responsible party and not as an indication that the third
party is or has become the financially responsible party or a client of Dr. Reid, nor an
indication that therapy has been provided.
Return of fees:
Though fees paid for services rendered are not returned even when an evaluation has not
been completed, you are not expected to pay for services that have never been performed.
Since fees for certain services (such as the report outlining the findings of the evaluation)
are paid in advance, certain circumstances (such as a settlement) may make it
unnecessary to perform services for which fees have already been paid. Under such
circumstances, fees paid in advance will be refunded. It must be understood, however,
that no refunds will be made until I have been formally notified, either by the Court or by
the attorneys for both parties, that it is the position of all involved that my task has been
completed, that no further services will be requested, and that I am discharged. Upon
5
Tolu v. Stientjes
receipt of such formal notice, a final account statement will be prepared and any funds
owed by me to the financially responsible party (parties) will accompany the final
account statement.
Limitations, Risks, and Services NOT provided:

The profession of psychology has not developed specific methods and procedures for use
in assessing comparative custodial fitness. The criteria that I employ and the methods and
procedures that I utilize have been chosen by me.
Unless instructed otherwise by the Court, I will, as the evaluation progresses, share
information (including preliminary impressions) with a Guardian ad Litem if one has
been appointed. Subsequent to the completion of my evaluation and prior to the
preparation of my report, I am willing to confer with the attorneys if such a conference is
desired by all involved and not objected to by the Court. Detailed information concerning
my findings, however, will be communicated in writing only. Be aware that the dispute is
not resolved with the issuance of my report. Though the information provided and
opinions expressed are intended to assist the Court, the Court may reject all or portions of
the information provided and/or may reject the opinions offered. Also recognize that,
though it has not yet occurred, the possibility exists that, even after having completed a
thorough examination of the issues, I may not be able to offer an opinion with a
reasonable degree of professional certainty. Neither under this circumstance nor under
circumstances in which completion of the evaluation becomes either impossible or
unnecessary are fees for services already rendered refunded.
It is not possible to guarantee that an evaluation will be concluded by a specific date.

Ordinarily, judges who have requested that forensic evaluations be performed wish to
have reports prepared prior to the commencement of a trial. Though quite unlikely, it is
possible that a judge will begin trial prior to receiving a report.
Reasonable steps are taken to minimize the distress associated with the evaluation
process. Although many cases are resolved without judicial intervention, I must presume
that there will be a trial and must conduct myself accordingly. This means that
information that you provide will be questioned and, at times, you may feel as though
you are being interrogated rather than interviewed. In order to perform my Court-ordered
function, I must be an examiner, not a therapist.
It must be understood that I cannot provide psychological advice to individuals whom I

am evaluating. If counseling or psychotherapy services are desired, I will be pleased to
provide the names of appropriate professionals. I cannot provide emergency assistance to
someone whom I am evaluating. If an emergency situation arises, assistance should be
sought through the police, the nearest hospital, or your attorney (depending, of course, on
the nature of the emergency).
Unless I have been directed otherwise by the Court, I will presume that all items in the
case file are discoverable (that is, subject to examination) by parties, their attorneys, the
6
Tolu v. Stientjes
attorney for the child(ren), and any expert(s) who may have been retained by counsel for
either party. In the event of a trial, unless I have been directed otherwise by the Court, all
items in the case file will be brought with me to Court any day that I am scheduled to
offer testimony.
If there is a trial and if you should request that I testify, I am obligated to maintain my
impartiality and openness to new information throughout the course of the evaluation and
during the trial. It is not my obligation to defend the precision of facts reported, the
accuracy of data interpretations made, or the validity of opinions offered in the face of
newly introduced information that might reasonably call them into question. Though it is
more likely than not that testimony offered by me will explain and be supportive of the
contents of my report, no assurances can be offered that this will be the case. A cross-
examining attorney may bring to my attention information of which I was unaware
(either because it was not brought to my attention during the course of my evaluation or
because it pertains to events occurring subsequent to the issuance of my report). The
attorney may ask how the new information might affect my professional opinion of you
and/or your spouse. I will, of course, respond honestly. You must recognize that I am not
an advocate for the person who seeks my testimony and that I am obligated to offer
any/all pertinent information that might be of assistance to the Trier of Fact. I must, for
example, provide information concerning your parenting weaknesses and your
spouse’s/partners’ parenting strengths. Put most simply, fees paid to me represent
compensation for time expended. The person paying my fees cannot be assured that my
testimony will be helpful to his/her case.
Opinions expressed by me in my report will be formulated on the basis of information

provided to me between the day on which I was initially contacted and the day on which
the report is prepared.
If any questions arise concerning legal matters, you must consult with your attorney. It is
inappropriate for someone not trained in the law to attempt to respond to questions
concerning legal matters.
Psychological Testing:
It is expected that when individuals being evaluated come to my office for the purpose of
taking psychological tests they will arrive unaccompanied. Spouses, children,
companions, and friends can serve as sources of distraction. If someone must transport
the test-taker, that person will be asked to leave and not return until the test-taker has
finished. You may not seek consultation during testing, copy test items, or make
recordings of the testing process.
Submission and retention of documents:

Ordinarily, in consultation with your attorney, it will be possible for you to anticipate
what documents I am likely to require. Obtaining pertinent documents prior to the
commencement of the evaluation will expedite the evaluative process. Any documents
submitted for my consideration must be sent to me by the attorneys and must be
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Tolu v. Stientjes
accompanied by statement verifying that the submitted items are simultaneously being
provided to other attorney(s) involved in the case.
Attorneys objecting to my consideration of materials submitted to me must inform me

within three business days of their intention to formally address their concerns with
opposing counsel and the children’s attorney. Documentation of efforts made to address
the issue with the other attorney(s) and/or the Court must be provided to me, with copies
to the other attorney(s), within three business days of the initial notice of objection. If
these steps have not been taken in the manner described and within the time frames
specified, I may elect to proceed with review of the submitted materials.
Because I may be called upon to produce all items (documents, tapes, photographs, etc.)
that I have considered in formulating my professional opinion, it is my policy to retain
any items that are presented to me for my consideration. You are therefore strongly
encouraged to make copies of any materials that your attorney intends to submit to me. If
you neglect to make copies and if you later require copies, you will be charged for time
expended in preparing copies. Documents and other items will be returned only after I
have been informed either by the Court or by attorneys for both parties that it is no longer
necessary for me to retain them. If, prior to trial, a lawful request is made that I copy and
release items in my file for examination by an attorney or by an appropriate reviewing
mental health professional, all involved will be notified. Unless an objection to the
release of the requested items is brought before the Court and honored by the Court, the
requested items will be released. (You are reminded that your signature on this document
will constitute an authorization to release requested items to those lawfully entitled to
receive them. Under most circumstances, those lawfully entitled to receive them include
the Court, the attorneys for both parties, and any consultants retained by the attorneys.)
The attorney requesting copies will pay the costs associated with producing the copies.
(Currently, the standard fee for photocopying is $.50/page. I reserve the right to charge a
higher fee for pages both sides of which must be copied and/or for items on non-standard
size pages (that is, other than 8.5” x 11”).
Obtaining additional information:

Individuals being evaluated must agree to authorize me to obtain any documents that I
may wish to examine and to authorize communication between me and any individuals
who, in my judgment, may have information bearing upon the subject of the assessment.
Where specific instructions concerning those to be evaluated (and how extensively they
are to be evaluated), information to be obtained, etc. has not been included in the Order
appointing me, the decisions concerning these matters will be made by me. There may be
instances in which I will be asked to review information that I reasonably believe is likely
to be more prejudicial than probative and instances in which I will be asked to contact
individuals whom it would, in my judgment, be inappropriate to contact. I must be the
final arbiter in such situations.
8
Tolu v. Stientjes
If you wish to have individuals write to me on your behalf, you must instruct the
individual to state: “I understand that the information I have provided is not confidential.”
The statement must be signed and the letter must be mailed directly to me. (Letters are
not to be forwarded to me by you or by your attorney.) Letters received by me will be
reproduced by me and furnished to the attorneys for the parties and the attorney for the
child(ren). It is your responsibility to explain to anyone from whom you solicit a letter
that the information contained in the letter may be revealed to any of the individuals
involved in the evaluation (including children, if necessary and appropriate) and may be
quoted in the report.
Contact with attorneys:

Once I have received word that I will be conducting an impartial evaluation of
comparative custodial fitness, I endeavor to avoid ex parte communication with the
attorneys representing the litigants. If a Guardian ad Litem has been appointed for the
child(ren), I will speak periodically to him/her and will exchange information with
him/her (unless instructed not to do so by the Court). In my judgment, our roles are
similar and it is, therefore, appropriate that we share information. During the evaluation,
oral communication with attorneys for the parties will occur only if it is not in
contravention of a Court directive, only if it can be done by means of a conference or
conference call, and only if unusual circumstances make such communication necessary.
If correspondence becomes necessary, it must be on a copies-to-all basis. Once the
evaluation has been completed and my report has been released, I will engage in oral
discussions with the attorneys if I deem it advisable to do so, if no objections to such
discussions are raised, and if such discussions are not in contravention of the Court’s
Order or subsequent directives.
Allegations of abuse/neglect:
It must be understood that I am required by law to report allegations of abuse or neglect
(even if they have been previously reported). The penalties imposed on mandated
reporters who fail to report such allegations are severe. If allegations are made, they will
be reported and my action in reporting them must not be interpreted as a display of
support for the individual who has made the allegations or as an indication that I
disapprove of the alleged actions of the person who has been accused. Most importantly,
it must not be inferred that my reporting of such allegations suggests that I find them
credible.
Appointments and Cancellations:

Because the scheduled appointment time is held exclusively for one person or task,
advance notice of cancellations is required. If the amount of notice of cancellations is one
full business day (24 hours) there will be no charge for cancelled time. If the amount of
notice of cancellation is less than 24 hours, full fee is required for the time reserved on
Dr. Reid’s calendar.
Medical Records: If Petitioner, Respondent, or any minor child or children is currently

being treated, or has ever been treated by a mental health professional (Psychiatrist,
9
Tolu v. Stientjes
Psychologist, Licensed Clinical Social Worker, Licensed Professional Counselor, or any

other type of counselor or therapist or treatment including hospitalizations) or has been
prescribed medications for psychiatric reasons, it is the responsibility of the parties(s) to
obtain and provide full and complete records from each and every treating source. An
attestation should accompany each record indicating that the documents represent the full
and complete file. Medical Records should be submitted by the provider directly to the
Guardian ad Litem, who will ensure that I am entitled to receive the records.
Disclosure and/or Release of Records:

Records maintained by Dr. Reid will only be released upon an appropriate order of the
Court. The retaining party will be responsible for the time involved in making
photocopies of the records requested.
Collection:
If an account is due for 60 days, it shall be sent for collection. The responsible party shall
pay all reasonable costs of collecting the bill, such as reasonable collection agency
charges, reasonable attorney’s fees and court costs. Any amount that a collection agency
charges shall be added to the bill and shall become part of the financial responsibility at
the time the account is sent to the collection agency. In the event that legal action is
instituted to collect fees and charges, the responsible party shall pay all additional
reasonable costs and fees resulting from the suit, such as reasonable collection agency
charges, reasonable attorney’s fees, and court costs and that the suit shall be filed and the
matter shall properly heard in St. Louis County, Missouri.
Termination:
Dr. Reid may immediately terminate his services at any time he reasonably believes that
any party is not fully complying with the provisions stated herein or with the orders of the
court. Dr. Reid may, at his sole discretion, immediately terminate his service if any party
related to this matter is not, or ceases to be, represented by counsel. No services
(including reports, recommendations, or opinions) will be provided after services are
terminated.
Agreement:
Your signature below indicates (1) that you have received, read, and understand my
policies and procedures; (2) that you recognize that neither the principle of confidentiality
nor the principle of privilege applies to any information in my file concerning this matter;
and, (3) that you are authorizing the release by me, either orally or in written form, of
any/all information in my file, including my report, to the Court, the Guardian ad Litem
for the child(ren), the attorneys for both parties, and qualified mental health professionals
retained to review my work.
With specific regard to information that might ordinarily be protected from disclosure by
HIPAA provisions, in signing this document, you acknowledge that pursuant to HIPAA
Section 164.512(e)(1)(i) of the Code of Federal Regulations, disclosures of otherwise
protected health information may be provided in the course of judicial or administrative
10
EXHIBIT 3
Electronically Filed - St Louis County - April
September
03, 2018
10,- 2020
09:34- AM
12:11 AM
EXHIBIT 4
Division 99
Division 35
2015
10, 2018
June 05,
Judge
Judge
April

Tolu v. Reid Et Al

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Tolu v. Reid Et Al

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Electronically Filed - St Louis County - September 10, 2020 - 12:11 AM

IN THE TWENTY-FIRST JUDICIAL CIRCUIT COURT

C. Facts Related to Breach of the Standard of Care and Breach of Contract

D. Facts Related to the Breach of Fiduciary Duty by Defendant Pudlowski 32 - 36

COUNT I Breach of Standard of Care Defendants Reid & Reid LLC 45 - 49

EXHIBIT 1 Court Order Appointing Pudlowski

Plaintiff, states as follows:

PARTIES, JURISDICTION AND VENUE

1. Plaintiff is an individual who resides in Saint Louis County, Missouri.

2. Defendant Reid is a Missouri licensed psychologist, with his principal place of

business in Clayton, Saint Louis County, Missouri.

James D. Reid, Ph.D., LLC.

proceedings, including divorce, child custody and child custody modifications.

“exercise his independent objective judgment in conducting the evaluation.”

6. Defendant Pudlowski is an attorney licensed to practice law in Missouri, with her

principal place of business in Clayton, Saint Louis County, Missouri.

7. Pudlowski is a certified, court appointed guardian ad litem (“GAL”), domestic law

8. Defendant Van Luven is a Missouri Licensed Clinical Social Worker (“LCSW”),

9. Defendant Fitzgibbons Psychological Associates is a professional entity conducting

employment, servancy and/or agency for Fitzgibbons.

and, therefore, venue is proper in Saint Louis County, Missouri.

COMMON FACTS AND ALLEGATIONS

A. Plaintiff’s Family History That Led to Plaintiff’s Divorce

the former Soviet Union.

15. On April 3, 2002, Plaintiff married Robert Stientjes (“Stientjes”).

disruptive in class and interfered with the teaching process.

presence of Child A and Child T.

was present or not.

to say and do the right things at the right time.

24. Plaintiff continued to focus Child A and Child T, on positive behaviors by

the abuse cycle.

Stientjes seeking his “suspension from practice before the IRS.”

behavior to Stientjes in showing disrespect and aggressiveness toward Plaintiff at the

helping survivors safely escape their abusers and thrive.

unlocked all over the family home.

LPC”) to help Plaintiff’s family with crisis intervention.

chair cushioning, wires, rubber, pencils and plastic items.

allowed to continue with therapy for Child T at Family Forward.

communicate with his mother without insulting her.

with Plaintiff, Child A and Child T.

time, the family dynamics in Plaintiff’s home were stable.

resident of Florida, which Plaintiff considered untruthful.

DR04088, Saint Louis County, Missouri, Circuit Court.

Plaintiff’s credit was also materially damaged.

custody modification proceedings, being case 16SL-DR04088-01).

B. Family History That Led to Plaintiff Seeking Modification of Child Custody

frightened Child T to her home.

knowledge and consent.

Plaintiff aggressive, disrespectful, hostile, and belligerent.

Stientjes’ house for scheduled custody time.

following the custody arrangements established in the Parenting Plan.

she did not have his permission to counsel either child.

and Stientjes interfered with Plaintiff’s attempts to see Child A.

proceedings on August 8, 2017.

pictures from that account to the teacher’s student body.

Child T against Stientjes.

from the trauma inflicted by Stientjes.

custody modification proceedings. A copy of Pudlowski’s Appointment Order is attached as

Exhibit 1 and made a part thereof.

minor children’s wishes.”[emphasis added].

required Memorandum of Compliance.

80. On October 3, 2017, Stientjes petitioned the Court to appoint a psychologist to