Final Corrected Copy Federal Suit

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
DEBORAH ORLANDO COONEY, RHONDA GRIFFITH- )

KRAUT, JULIA BORNHUETTER-COLLOTON, and others )
Similarly situate )
)
PLAINTIFFS )
)
-vs- )
)
LYLE ROSSITER, JR, M.D.; KATHRYN BISCHOFF; ) Jury trial demanded
BRIAN KLAUNG; JUDGE STEVEN NORDQUIST; )
JOHN BUDZYNSKI; PAUL A. LOGLI, STATE’S ) No.
ATTORNEY; DEPARTMENT OF CHILDREN AND )
FAMILY SERVICES BY EDWIN MCEWEN, ACTING )
DIRECTOR; ADMINISTRATIVE LAW JUDGE DANIEL )
BAECHLE; DAVID JACOBSEN, BRENT JOHNSON OF )
DEPARTMENT OF CHILDREN AND FAMILY )
SERVICES; ROCKFORD PUBLIC SCHOOLS; )
DANIEL J. CAIN; EDWARD J. KEUER, M.D. )
)
DEFENDANTS )
CLASS ACTION COMPLAINT
Plaintiffs, Deborah Orlando Cooney hereinafter known as Deborah, Rhonda Griffith-

Kraut hereinafter known as Rhonda, and Julia Bornhuetter-Colloton hereinafter known as
Julia, bring this class action complaint against the Defendants herein to seek redress for
themselves and all others injured by the actions of the Defendants as set forth hereinafter:
NATURE OF THE CASE
1. The Defendants have been active participants in the cases involving minor
children either born to them during marriage or as a result of a relationship.
2. That each of the defendants have acted in consort to deprive the Plaintiffs,
individually and other members of the class of their constitutional rights of due
process under the Federal Constitution by depriving them of custody of their
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children without due process; without a hearing, in violation of various statutory
provisions; falsifying “docket sheets” which are the official record of court
proceedings, and other actions as more fully set forth.
3. Those actions were a proximate cause of the Plaintiffs’ and other members of the
class sustaining substantial emotional and physical injury to themselves, and their
children by being deprived of the society of each other pursuant to the Constitution
of the United States of America.
4. On behalf of the Plaintiffs and other members of the class, the Plaintiffs seek
redress for that misconduct as described hereafter.
PARTIES
1. Plaintiff Deborah is a resident of the State of Illinois and residing in Cook

County, Illinois; Plaintiffs Rhonda and Julia are residents of Winnebago County,
Illinois.
2. Defendants are residents of the State of Illinois and reside in various counties in
Illinois, including Winnebago County, Illinois.
JURISDICTION
The court has original jurisdiction over this complaint pursuant to 28 U.S.C.
Section 1331 which states “The district courts shall have original jurisdiction of
all civil actions arising under the Constitution, laws, or treaties of the United
States”.
VENUE
Venue is proper in this district, inter alia, 28 U.S.C. Section 1391 (b) (2). Plaintiff
Deborah is a resident of the City of Chicago, County of Cook and State of Illinois
and has been for eleven (11) years continuously. The acts alleged as being
perpetrated by Deborah took place in Chicago, County of Cook, Illinois.
FACTS
The Defendants named above and their respective positions in the numerous
violations of the Plaintiffs’ rights are as follows:
A. Lyle Rossiter, Jr., M.D. was duly appointed a 750 I.L.C.S 5/605 evaluator in
a post judgment custody matter in the case entitled In Re: The Marriage of
Deborah Orlando Cooney v. Lorenzo Orlando (EXHIBIT #1). His report
(GROUP EXHIBIT #2), which was false, misleading and predicated upon
stale / limited information led to the immediate transfer of custody, see
Petition and Order (GROUP EXHIBIT #3) and an exparte emergency order
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of protection (GROUP EXHIBIT #4) being entered on June 15, 2005, by
Judge Steven Nordquist.
On Oct. 7, 2005 conducted a critique of Dr. Rossiter’s 605 custodial

evaluation of the Orlando case. Dr. Alan Jaffe’s opinion of the custodial
report authored by Dr. Rossiter was that it was an example of
“confirmatory bias” (GROUP EXHIBIT #2) Dr. Jaffe’s CV attached
(GROUP EXHIBIT #2) Dr. Jaffe administered a MMPI 2 and ASPECT test
to Plaintiff, Deborah, in which the findings were in complete contradiction
to the reported findings in Dr. Rossiter’s report. (GROUP EXHIBIT #2). Dr.
Jaffe testified in Deborah’s Administrative hearing.
B. Judge Steven Nordquist was the Judge who presided over the Matrimonial
action between Deborah Orlando Cooney v. Lorenzo Orlando, 93D 1332. It
was he who entered a series of orders beginning with the emergency order
of protection and the immediate transfer of custody on June 15, 2005, and
continued violating the constitutional rights of the Plaintiff and her children
by continuing the “emergency order of protection” without granting the
Plaintiff a hearing on termination of same for a period of eighteen (18)
months. The order entered by Judge Steven Nordquist on June 15, 2005,
also provided for no contact between Deborah and her two minor children,
Jonathan, then 13 ½ years of age and Christopher , then 15 ½ years of age.
That the aforesaid orders were entered without notice and without a hearing.
See court transcript of 6-15-05 (EXHIBIT #5). Judge Steven Nordquist also
entered a series of court orders in cases involving the other two named
Plaintiffs in cases entitled In Re: the Marriage of Julia Bornhuetter-Colloton
vs Douglas Colloton as well as in the case entitled Rhonda Griffith-Kraut vs
Giles Denham. In all three of the aforementioned cases Judge Steven
Nordquist violated the Constitutional Rights of the plaintiffs by entering
orders transferring custody of children to the fathers as well as other orders
that transcend the Constitutional Rights of the plaintiffs and their children.
C. Kathryn Bischoff was the attorney duly appointed by Judge Nordquist as the
child representative (EXHIBIT #6), charged with the responsibility of
protecting the minor children in all three cases. She participated with Judge
Steven Nordquist and Dr. Lyle Rossiter to deprive the Plaintiff, Deborah of
her rights, and the rights of her children. Specific acts will be set forth
hereafter. Kathryn Bischoff also committed various acts in detriment to the
Constitutional Rights of the two other named Plaintiffs and their children,
all as set forth hereafter.
D. Brian Klaung was the “therapist” selected by the father, Lorenzo Orlando, to
provide therapy for the Orlando children. It will be shown that this
participant clearly violated the Plaintiff, Deborah Cooney’s, rights and the
children’s rights; he lied under oath, and was the reporter to DCFS. Brian
Klaung never met, interviewed, or even spoke to Plaintiff, Deborah as of the
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date of filing this complaint. This report to DCFS resulted in an indicated
finding issued against Deborah, on Sept. 12, 2005, in a case that took 564
days to complete from the day Deborah filed her notice of appeal on Sept.
14, 2005 to the entry of the order entered on March 30, 2007 by DFCS’
Acting Director, Edwin McEwen. The Administrative Law Judge, Daniel
Baechle who presided over the Administrative proceeding entitled Deborah
Orlando Cooney, Appellant, clearly violating the due process rights of
Deborah Cooney to a final dispositional order within 90 days from the filing
of the notice of appeal, which is in violation of Illinois Administrative Code,
Title 89, 336.220 (a). (GROUP EXHIBIT #7).
E. Besides the Department of Children and Family Services violating the

strictly adhered to “ninety day rule”, there were numerous other Department
and Illinois Administrative Code violations that stripped Deborah of her
constitutional rights of due process, as follows: Illinois Administrative
Code, Title 89, 300.110 (c) “provides that in a formal investigation, an
investigator must have in-person contact with the alleged victim, the
alleged perpetrator, and the child’s caretaker”. Deborah was never
interviewed in person or otherwise, even though she (Deborah) personally
appeared at the DCFS’ offices as acknowledged by Robert Coffey,
investigator for DCFS, in his testimony at trial before the ALJ, Daniel
Baechle. Investigator Robert Coffey misrepresented statements by Dr.
Sawar Husain, see statement and affidavit (GROUP EXHIBIT 8).
Investigator Robert Coffey did not go to the source of the medical
information; instead accepted the word of Lorenzo Orlando (Plaintiff’s ex-
husband) and the opinionated unsigned custodial draft report of Dr. Lyle
Rossiter, Jr. duly appointed 750 ILCS 5/605 evaluator, see extrapolated
transcript (GROUP EXHIBIT #8). The only items that Mr. Coffey relied on
were a draft unsigned report and statements from Lorenzo Orlando. Mr.
Coffey contacted no other medical source and he did not contact Dr.
Lawrence Goslawski, psychiatrist treating Christopher Orlando for 1 ½
years or Dr. Sawar Husain, internist treating Christopher for 1 ½ years,
whose statement made to DCFS was misrepresented in Mr. Coffey’s report.
(GROUP EXHIBIT #8). DFCS Administrative Rules mandate that the
investigator go to the source of any medical treatments. Robert Coffey,
during cross-examination on Oct. 26, 2006, at the Administrative Hearing
testified that if had he known of the extent of missing medical information
for the years of 2003, 2004 and 2005 in Dr. Rossiter’s report then he would
have done his job and gone to the sources directly, as mandated. See
extrapolated transcript (GROUP EXHIBIT #8). Additionally, notes in the
DCFS Investigative file reveal that No HIPAA release was obtained and no
written document of the child’s deterioration from a mental health view
point was received from the mandated reporter, as required. See Illinois
Administrative Code Title 89, 300.110(d). This contravened the
requirements as set forth by Brent Johnson, Supervisor of Robert Coffey, on
page 14 of the DCFS’ Investigative File (GROUP EXHIBIT #8).
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F. Department of Children and Family Services’ Administrative Law Judge
(ALJ), Daniel Baechle, violated Illinois Administrative Code, Title 89,
336.120 (a)(4) which states that the ALJ, Daniel Baechle, shall not have a
personal or professional interest that interferes with exercising objectivity or
have a bias against the parties or issues appealed. Administrative Law
Judge, Daniel Baechle was requested to recuse himself on March 16, 2006
due to his personal and professional relationship with Kathryn Bischoff,
Child Representative. Administrative Law Judge Daniel Baechle refused to
recuse himself on May 25, 2006, and proceeded with Appellant’s hearing on
Appeals of a finding. See Petition for Substitution of Judge and the ALJ’s
order (GROUP EXHIBIT #9).
G. DCFS’ Administrative Law Judge, Daniel Baechle, denied the Plaintiff,

Deborah Cooney, the right to add a witness, Rhonda Cassady, in order to
access the Department of Children and Family Services’ records relating to
the Amended allegation on Aug. 14, 2006 (GROUP EXHIBIT #10), which
came about a year subsequent to the finding against the Plaintiff, Deborah.
DCFS’ Amended Allegation had no new additional facts. The ALJ, Daniel
Baechle violated Illinois Administrative Code, Title 89, 431 and Illinois
Administrative Code Title 89, 336.100 (h). On occasion during the
Administrative hearing, ALJ, Daniel Baechle, as the record will show,
denied the Plaintiff, Deborah, the right to enter into evidence medical
records from Swedish American Hospital that would demonstrate no
psychological pathology for Christopher Orlando requiring any form of
hospitalization and / or medication. This clearly violated DCFS’ very low
standard and liberal treatment of entry of evidence into hearings. Yet, Judge
Daniel Baechle allowed Rossiter’s report (based on multiple hearsay, stale
and limited medical information) into evidence, without foundation, simply
because it was stapled to the investigative report.
H. Daniel J. Cain who on June 14, 2005, when Judge Steven Nordquist ordered
a “gag” order that stipulated that counsel was not to disclose the contents of
Dr. Rossiter’s report to their clients; failed to disclose to the court that he
(Dan Cain) on information and belief had in his possession the report
authored by Dr. Rossiter. (EXHIBIT #11). Dan Cain prepared and had his
client, Lorenzo Orlando, sign and notarize an Emergency Petition for
Change of Custody with exact phrases directly extrapolated from Dr.
Rossiter’s Report on June 13, 2005. (EXHIBIT #3). Deborah’s attorney,
Alex Abate had an obligation to his client (Deborah) and as a result of Judge
Steven Nordquist’s “gag” order of June 13, 2005 was forced to violate
Illinois Rules of Professional Conduct Rule 1.1, Rule 1.4 (a), 1.4(b), Rule
2.1, Rule 8.4(1), 8.4(2) and 8.4(4), all of which violates Article VIII of the
Illinois Supreme Court rules. Daniel Cain allegedly committed a fraud upon
the court and as a result of this alleged fraud, Judge Steven Nordquist
entered a “gag” order of June 14, 2005 (EXHIBIT #11) that prevented her
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(Deborah) attorney from disclosing Dr. Rossiter’s report and preventing her
(Deborah) attorney from properly representing her (Deborah) in court the
next day on June 15, 2005, see transcript (EXHIBIT #5). Plaintiff,
Deborah’s, attorney Alex Abate abided by the court’s “gag” order of June
14, 2005 and refused to disclose to his client, Deborah, the contents of Dr.
Rossiter’s report or what events were to take place in court the next day on
June 15, 2005. Plaintiff, Deborah, was the only party who did not know of
the contents of Dr. Rossiter’s report, a 605 court appointed evaluator, until
court on June 15, 2005 which violated the statute for 750 ILCS 5/605 which
states that parties shall receive the report 10 days prior to a hearing, the right
to cross-examination can not be waived, and parties are entitled to all
underlying documents used by the 605 evaluator.
I. Edward J. Keuer, M.D. testified on Oct. 25, 2006 that he was contacted
twice by Attorney Dan Cain, who represents Plaintiff, Deborah Cooney’s
ex-husband, Lorenzo Orlando, see extrapolated transcript (GROUP
EXHIBIT #12). Keuer’s statement to DCFS, on Sept. 8, 2005 (3 ½ years
after his 10 minute consultation in Jan. 2002, at which time Keuer did no
test or skin biopsies), was that: “Christopher was not actually his patient
and then further states that he recalls the lesions on Christopher and
they did not match up to what Christopher’s mother was saying they
were, but he did not have records to go in and see what the diagnosis
was”. (GROUP EXHIBIT #12).
Dr. Edward Keuer testified that Attorney Cain contacted him in 2002 and
requested that he (Keuer) write a narrative concerning Christopher Orlando
(minor), son of Plaintiff Deborah and Lorenzo Orlando. Dr. Edward Keuer
saw Christopher (minor) in Jan 2002 for about a 10 minute consultation for
skin sores with no follow-up thereafter. Dr. Edward Keuer then wrote a 4
page narrative almost 30 days later, at the request of Dan Cain, who
represented Lorenzo Orlando in a custody suit against Plaintiff, Deborah.
(GROUP EXHIBIT #12). Said narrative was not for medical reasons but
was written and sent to Sreenan and Cain to assist in the custody suit.
Deborah Cooney had sole care and physical custody of the minors,
Christopher and Jonathan Orlando. Dr. Edward Keuer never obtained
consent from Deborah Cooney, nor did he (Keuer) provide Deborah Cooney
with a copy of the Narrative which was sent to Dan Cain’s office.
Dan Cain presented alleged documents to Rockford Police Detective, Dan

Marino, in 2003, in order to thwart a child abuse investigation by his client,
Lorenzo Orlando, of the minor (Christopher). Detective Marino never
contacted the minor’s (Christopher’s) treating physicians in Chicago, where
Plaintiff, Deborah, resided, but instead showed photos to doctors in
Rockford who never medically treated Christopher Orlando. Copies of these
documents, photos, and letters presented by Dan Cain, were not attached to
the Rockford Police Detective Report of Child Abuse, when subpoenaed on
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June 25, 2004. This resulted in Detective Marino closing a child abuse
investigation. (GROUP EXHIBIT #12).
Dr. Edward Keuer’s office was later subpoenaed and the Plaintiff, Deborah
Cooney, later obtained a court order, on or around December 8, 2005
(GROUP EXHIBIT #12) for any and all records of Christopher Orlando.
Plaintiff, Deborah Cooney, was informed by Dr. Keuer’s secretary, Dana
that: Dr. Keuer was instructed by Dr. Lyle Rossiter not to speak with
Plaintiff, Deborah; Dr. Keuer did not have a file for Christopher Orlando;
Christopher was not seen by Dr. Keuer in the office; and no such Narrative
existed. Loyola Medical Center, location where Dr. Keuer consulted on
Christopher Orlando in Jan. 2002, was subpoenaed Aug. 24, 2005 for any
and all records for Christopher Orlando. (GROUP EXHIBIT #12). Said
Narrative was not found in Christopher’s medical records at Loyola Medical
Center. Dr. Rossiter contacted Dr. Keuer’s office on May 27, 2005 via
telefax providing Dr. Keuer with a copy of the Narrative and informing him
that Plaintiff, Deborah, was challenging his credentials. (GROUP EXHIBIT
#12).
J. John Budzynski, LCPC., has been the therapist for the Colloton children
since August, 1998 and remains, so to date. See letter dated Feb. 13, 2001
(GROUP EXHIBIT 13). John Budzynski in Feb. 13, 2001 letter to James
Schoonhaven of ADDUS Health Care and Family Services, informs him
that the decision for supervised visitation was made by Kathryn Bischoff,
Robert Canfield (counsel for Douglas Colloton) and himself (John
Budzynski). In said letter, John Budzynski, wrote statements that
misrepresent facts, wherein he wrote: “Ms. Bournhutter has a history of
false reports to DCFS (at least five) stemming from allegations against
Mr. Colloton. Ms. Bournhutter has also been sent a letter from State
Attorney Paul Logli’s office threatening legal action because of a false
report that she filed against Mr. Colloton alleging domestic violence /
battery.” In contradiction to John Budzynski’s letter to James
Schoonhaven, there are facts that prove that Julia Colloton’s reports of
domestic violence, alleged molestation, bruising on her daughters have been
confirmed by collateral resources. Police report of 11-26-97 of domestic
trouble / domestic battery (GROUP EXHIBIT #13).
Further, John Budzynski in a letter dated Oct 27, 1998 to Assistant States’
Attorney, Mr. Linzy, recommends that the Colloton children should not be
put on a witness list to testify about events of domestic battery case filed by
Plaintiff Julia against Douglas Colloton. See letter. (GROUP EXHIBIT
#13). Oct. 28, 1998 letter from Kathryn Bischoff to Budzynski, in which she
wrote: “I and Mr. Linzy met with the Colloton children last evening to
review the alleged incident. At the end of the interviews Mr. Linzy
informed me that he will not be calling the children to testify in the
domestic battery case Mrs. Colloton filed against Mr. Colloton. …. I
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appreciate your efforts in this matter and if you still wish to send the
letter to Mr. Linzy, it would be appropriate.” See letter (GROUP
EXHIBIT #13). Kathryn Bischoff worked in consort with John Budzynski to
prevent the facts from coming to light.
In contradiction to John Budzynski’s statements, the Court Order of Dec.

19, 1997 states that: the court finds that Plaintiff Julia has been abused and
is entitled to an extension of Order of Protection (GROUP EXHIBIT #13)
Attached is Plaintiff Julia’s Plenary Order of Protection against Douglas
Colloton (GROUP EXHIBIT #13). An opinion on Jan. 25, 1999 by the
court of claims found that Plaintiff Julia was a victim of a violent crime on
Nov. 26, 1997 and that she (Julia) is awarded compensation.
On Sept. 15, 2000 John Budzynski wrote to Kathryn Bischoff a letter and
stated therein: “The greatest of my fears in this last report to IDFCS.
Since this last report is in conflict with my clinical observation of the
relationship between Natale and Douglas, I have to question the origins
of the supposed evidence of abuse that Attorney Bischoff reported to me
that the examinating Doctor documented.” He further wrote: “it is
inconceivable that Douglas could have perpetrated such an act. I fear
that Julia might have stepped over yet another line and fabricated this
incident complete with evidence and documentation by a physician who
is not familiar with Julia’s tactic or this case”. See letter (GROUP
EXHIBIT #13). John A. Budzynski, who has been the therapist for the
Colloton minors since August 1998 testified on Oct. 13, 2000 with presiding
Judge Steven Nordquist, that he felt that Natale fabricated the story of being
sexually molested by her father Douglas Colloton. Budzynski stated during
cross examination that he was not a mandated reporter after a report or an
investigation was made. Budzynski further stated that he did not investigate
Natale’s claim of being molested by her father nor did he contact the
treating doctor, Al Baris, M.D. at Swedish. Budzynski did not report to
DCFS or authorities that Natale, again, stated that she was molested by her
father, Douglas Colloton, because he felt the allegations were untrue.
Budzynski stated on Oct. 13, 2000 “I do believe the report has been
unfounded. I’ve seen a letter to that effect.” See extrapolated transcript
(GROUP EXHIBIT #13).
Note from Swedish American Health System Emergency Department

discharge instruction of 9/7/00 stated: Natale, minor, of Plaintiff Julia, was
treated by Al Baris, MD. Natale’s diagnosis was: history of possible sexual
abuse. Follow-up with DCFS and police investigation. Recheck if any
increased redness, pain or drainage (GROUP EXHIBIT #13). DCFS
completed their investigation of reported sexual abuse on Dec. 22, 2000 and
recommendation was that report was unfounded (GROUP EXHIBIT #13).
DCFS Investigative file was not released to Julia Colloton and was kept in
the Inspector General office. Query: How did John Budzynski know and
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testify on Oct. 13, 2000 that the reported sexual abuse of Natale would be
unfounded, when DCFS’ final determination was not written until Dec. 22,
2000?
In Plaintiff Rhonda’s case, Kathryn Bischoff, the court appointed Child

Representative in the Griffith case continued to recommend the services of
Budzynski, aware of the fact that he (Budzynski) does not consider himself
to be a mandated reporter and he does not report allegations of sexual abuse
to authorities nor to DCFS as he stated in his testimony on Oct. 13, 2000 in
re: Marriage of Douglas Colloton vs Julia Colloton. As noted in letter of
Oct. 17, 2005 from Kathryn Bischoff to Plaintiff, Rhonda. (EXHIBIT #14).
K. Paul A. Logli, State’s Attorney of Winnebago County and his office ASA,
Michelle Rock, writes a letter dated June 8, 1998 to Julia Colloton which
states: “It has come to the attention of this office that on May 15, 1998,
you reported to the police that Douglas verbally abused you.” ASA,
Michelle Rock, further writes: “If this office is notified in the future of
this or any similar activity, we will consider authorizing a criminal
complaint against you and a warrant for your arrest.” (GROUP
EXHIBIT #15) Julia Colloton on Dec. 19, 1997 was already recognized by
Winnebago County court as being a victim of a violent crime on 11-26-97 at
the hands of Douglas Colloton. The Court granted Julia a plenary order of
protection against Douglas Colloton on Dec. 19, 1997 (EXHIBIT #13)
Therefore, on June 8, 1998, when the Assistant States’ Attorney, Michelle
Rock, wrote to Julia Colloton, there was in place a valid plenary order of
protection signed by Judge Zenoff in Winnebago County court against
Douglas Colloton. The States’ Attorney office failed to protect Julia already
recognized as a victim of domestic violence by Douglas Colloton.
There is additional evidence to suggest that the office of Paul Logli, further
was involved in the Judicial Commitment of Julia to a local State Funded
Mental Facility on October 10. 1997, with no evidence, hearing and
complete disregard of the Constitutional rights of Julia and her children.
(GROUP EXHIBIT #15). See case note of Oct. 10, 1997 from Janet Wattle
Center stating: “the detectives were subsequently directed by States
Attorney – Paul Logli to have h/b (husband) write MHDD #5 followed
by that Office’s issuing a MHDD #7, to detain and examine cl at state
op.” (GROUP EXHIBIT #15) Oct. 10, 1997 Pre-Admission notes which
state “Attorney Paul Logli who decided to by pass the clinic staff …”
(GROUP EXHIBIT #15). Please note, the commitment was at the behest of
Douglas Colloton, Bishop Doran of the Catholic Church, Father Eric Barr
and Robert Canfield, attorney for Douglas Colloton. See Police report dated
10-9-97 in which Barr, a priest at St. Rita’s stated that he received a phone
call from Douglas Colloton stating that Julia was talking crazy and made a
statement that she was gonna kill that f _ _king satanic priest. (GROUP
EXHIBIT #15).
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Discharge transfer summary from Singer Mental Health on 10-14-97 which
states: “It is reported that her husband said she had bought a 9 mm
handgun and wanted to commit suicide and take others out with her.
There is no evidence of this. This was also the finding of Dr. Grace
Thundiyil, that the patient was not homicidal or suicidal at admission.
The patient was found to not be in any need of inpatient hospitalization
at this point, and was discharged on 10/14/97. This admission was
longer than anticipated because of the Columbus Day holiday.”
On Oct. 12, 1997 Fr. Eric R. Barr, pastor of St. Rita’s Catholic Community
informed Julia that she may not enter St. Rita’s property at any time, see
letter (GROUP EXHIBIT #15). All of these events took place due to the
allegations made by Douglas Colloton, against the Plaintiff Julia, which
coincidentally occurred with Douglas filing for divorce on Oct. 15, 1997
from Julia.
On April 22, 2004, John Budzynski used the office of State’s Attorney, Paul
Logli, to file Witness Harassment charges against Julia Colloton using an
alleged police report from Roscoe, Illinois Police Department, Jaime Evans.
Plaintiff, Julia, was “pro se” in re: the Marriage of Douglas vs. Julia
Colloton and had a right to contact any witness on a witness list in
preparation for a hearing. Motion for Protective Order filed on 8-25-04 by
Wendy Larsen Assistant States’ Attorney attached (GROUP EXHIBIT #16).
According to Winnebago County Courthouse, Julia was marked #4 as a
security risk on the revised list of Sept. 21, 2005. (GROUP EXHIBIT #16).
Note that Julia was on a security list, marked as #3, since Oct. 2001.
In Plaintiff Deborah’s Case: A Rockford Police officer badge #537 was

called to home address 7334 Montmorency in Rockford on Aug. 22, 1995
during the morning. Plaintiff, Deborah reported that a van with plate
#GU8898 was parked out in front of her house and that she saw someone
within the van. The Plaintiff, Deborah, informed the officer that she
(Deborah) had a valid Order of Protection against her ex-husband, Lorenzo
Orlando and he had been harassing and threatening her. The van plate of
GU8898 was checked and was reported to be registered to a private
detective of the Rockford Detective Agency, Don Roberts. The officer
checked with the State’s Attorney’s office and was informed that “these
actions were not a violation of the order of protection” and no further
action was taken. See Police Report #95-037038 (GROUP EXHIBIT #17).
Prior to this call on Aug. 22, 1995, to the Rockford Police Department, there
were in existence the following reports all against Plaintiff’s ex-husband,
Lorenzo Orlando: (1) Report #93-150993 Domestic battery dated 11-11-93;
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(2) Report #93-951049 Phone harassment dated 11-11-93; (3) Report #94-
001219 Disorderly conduct dated 1-9-94; (4) Report #94-004983 Public
Complaint Eavesdropping dated 2-3-94; (5) Report #94-004282 – Violation
of Order of Protection dated 1-30-94; (6) Report #94-009101 – Violation of
Order of Protection dated 3-1-94; (7) Report #94-015389 – Violation of
Order of Protection dated 4-7-94. In addition, on April 15, 1994 in the
Rockford Register Star – an article titled “Husband accused in phone tap”
was about Lorenzo wire tapping Deborah’s phone lines. Letter from
Virginia Gemignani, States Attorney’s office dated April 19, 1994 stating:
that “Deborah Orlando Cooney, was a victim of an eavesdropping.
Lorenzo Orlando has been arrested and indicted by a grand jury.”
(GROUP EXHIBIT #17). It is evident that Paul Logli’s State Attorney’s
Office is not doing their job in protecting the public, or anyone with a valid
Plenary Order of Protection.
L. Department of Children and Family Services - In Plaintiff Julia’s case: A

Letter from Rosecrance to Julia dated April 4, 2007 wherein David Gomel
writes: “we placed a call into DCFS hotline regarding the alleged past
abuse that Kristin disclosed during the assessment (which she also
informed us had been called in prior). DCFS reported to Rosecrance
that they will keep the call on record for the next six months, but will
not be investigating the issue further.” (EXHIBIT #18).
In Plaintiff Rhonda’s case: On Oct. 19, 2004 Giles Denham’s counsel,

Cheri Greenlee, filed a Motion for Appointment of Custody Evaluator.
Judge Steven Nordquist on Nov. 2, 2004 ordered that: “pursuant to 750
ILCS 5/605, the Illinois Department of Children and Family Services is
hereby appointed to conduct a Custody Investigation regarding what
custodial and visitation arrangement is in the best interest of Cheyenne
Renee Griffith and to submit a written report as to its conclusions
which shall be admitted into evidence as the Court’s exhibit.” (GROUP
EXHIBIT #29).
On Nov. 24, 2004 Plaintiff, Rhonda’s counsel Sharon Scott received the
DCFS investigative file in response to a request of an appeal of a finding
against Rhonda. (GROUP EXHIBIT #29).
On Feb. 9, 2005 DCFS’ Director, Bryan Samuels, granted Rhonda’s appeal

for the expungement of the finding. DCFS’ ALJ Gary Golian wrote: “The
administrative law judge is convinced that the Department failed to
meet the burden of proof with regard to the allegation that Appellant
placed her daughter at substantial risk of physical injury by taking her
to eat at a restaurant before leaving to place her in a Psychiatric
hospital. Therefore, it is recommended that the Appellant’s request for
expungement of allegation #60 from the State Central Register be
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GRANTED”. Recommendation signed by DCFS’ ALJ Gary Golian on Jan.
28, 2004 (GROUP EXHIBIT #29)
On Jan. 28, 2005, Attorney Sharon Scott for Plaintiff Rhonda telefaxed to
Linda – DCFS a Court Order signed by Judge Nordquist on Dec. 1, 2004
ordering DCFS to Open DCFS Case. (GROUP EXHIBIT #29).
On March 1, 2005 Illinois Department of Children and Family Services

(DCFS), by its attorney, Lisa Madigan, Attorney General of Illinois, and
through Khang P. Trinh, Assistant Attorney General filed Motion to Vacate
December 1, 2004 Court Order. Judge Steven Nordquist heard the Motion
on 3-3-05 and then “denied” the Motion. See docket sheet for 3-3-05 and the
court order dated 3-3-05. (GROUP EXHIBIT #29).
Another issue involving DCFS, on 1-13-05 Plaintiff, Rhonda telefaxed from

Dave Winter’s office (State Representative) a five (5) page letter to Kathy
Roman, with c.c. to Bryan Samuels and Rod R. Blagojevich. Therein
Rhonda wrote: “On this date of 1-12-05 I appeared for a hearing on
denial of services and the appropriateness of services. I appeared before
ALJ Gary Golian and Ann Marie Brandenburg, was previously assured
that I could present witness [sic] and evidence but was subsequently
denied my right to a complete hearing, due process, or the right put
evidence before DCFS.” Rhonda informed Kathy Roman, Assistant Deputy
Director of DCFS, that the 5 pages faxed to her are regarding the denial of a
hearing on a service plan and a custody evaluation in which DCFS ALJ
Gary Golian stated “we are not going to deal with that. Judge Nordquist
can deal with it”. (GROUP EXHIBIT #29).
In early 2006, the three (3) Plaintiffs, Deborah, Rhonda, and Julia contacted
and met with Dave Winters, State Representative, to ask for his assistance
with the Winnebago County Court System. Representatives of the
community and counsel for one of the Plaintiffs was present. State
Representative, Dave Winters, reported to the Plaintiffs that he would be
contacting DCFS, and Chief Justice Kathryn Zenoff to address Plaintiff’s
issues.
On Feb. 10, 2005, Plaintiff Rhonda telefaxed a letter to Mary Morrison,

Child Welfare Specialist at DCFS wherein Rhonda wrote: “I am writing to
you with the hope that you will arrange visitation for me with daughter,
Cheyenne Griffith. It has been 5 ½ months since I last saw her. The
Judge in our family courts ordered visitation on Dec. 1, 2004. In 10
weeks the IL. Depart. Children & Family Services has not made it
possible for me to neither speak with or visit my child.” (GROUP
EXHIBIT 29).
12
On Feb. 14, 2005, Rhonda sent a letter to Mary Morrison and / or Linda
Conti of DCFS wherein Rhonda wrote: “It is my hope that you will
consider the traumatic effect this separation has had on Cheyenne.”
On March 16, 2005 DCFS, Mary Morrison telefaxed a letter to Rhonda

wherein Morrison wrote: “Please be advised there is a supervised visit
arranged for you to see your daughter, Cheyenne on Wednesday March
23, 2005 at the DCFS building at 200 S. Wyman, Rockford, IL 61101
from 4-5 pm”. (GROUP EXHIBIT #29). Query: Why did it take 6 ½
months for DCFS to arrange for the visitation between Rhonda and her
daughter Cheyenne?
On March 23, 2005, Rhonda received letter from Mary Morrison, DCFS
which stated: “the visits between only you and your daughter will be on
Wednesdays from 4-5 pm at the DCFS office supervised.” (GROUP
EXHIBIT #29).
DCFS Service plan of 4-1-2005 and revised on 9-13-2005 for Rhonda.

On July 22, 2005, Rhonda wrote a letter to Jim Schoonhoven , Director and
Administrator of ADDUS Healthcare wherein Rhonda wrote: “On July 20,
2005 I attended a supervised visit with Cheyenne and Sally (an Addus
worker) at the Addus office. Cheyenne was playing with dolls and
visiting with me when she blurted out, “My Daddy and I play a game
where I pull his pants down and he runs into his bedroom.” I did not
say anything as I was waiting for Sally to take notice as she was
supervising the visit. Sally looked up from her paperwork that she was
doing, she and I exchanged glances but nothing further was said. Sally
did not question Cheyenne about this statement.” (GROUP EXHIBIT
#29). Sally is a worker of ADDUS Healthcare where this facility supervises
visitation between parents and children per court orders. Sally Forcier never
reported the statement that Cheyenne made to DCFS about the “game”
between her (Cheyenne) father and herself. Sally Forcier is a mandated
reporter and did nothing to protect Cheyenne.
Multiple calls have been made, letters written, and visits were made in
person to DCFS by numerous professionals. Letter from Tiffany Meek of
WAVE to Judge Gary Golian dated Jan. 12, 2006 (GROUP EXHIBIT #19).
Jamie Redders, therapist treating the minor, Cheyenne, wrote to Kathryn
Bischoff on July 15, 2004 and informed her that: “I personally have
witnessed Giles presenting angry, agitated, and anxious. I am not yet
convinced that Giles is the healthy parent.”(GROUP EXHIBIT #19).
Letter dated June 25, 2003 written by Teresa Hancock therein wrote: “when
Annie (Cheyenne) was 6 years old she revealed some disturbing
13
information about treatment she had received from her father and
Sandy, his girlfriend, while visiting their home. Giles Denham had
called her (Cheyenne) “bitch”, “bastard” and “bad names” and sent
her to a bedroom when she was unwilling to discuss court details
pertaining to Rhonda”. Annie further stated that on a separate occasion
Sandy had choked her (Cheyenne) while demonstrating with little
hands wrapped around her throat.”(GROUP EXHIBIT #19). Letter
dated May 21, 2004 written by Pastor Jerry DeMond of Halsted Road
Baptist Church to Mrs. Jamie Redders. Pastor DeMond writes: “When her
(Cheyenne) mother arrived, the very first thing that Cheyenne said, “do
I get to stay with you?” her mother told her that she had to take her
back to her father. I don’t think I shall ever forget the horror of the
crying and despair that that child showed. It was as if she were being
forced to do something that she feared”. (GROUP EXHIBIT #19).
Letter dated Oct. 17, 2004 written by Jean L. Martin to Brian Samuels,
Director Illinois D.C.F.S. in which she wrote: “Cheyenne has said in front
of me: she wants to live with her mother, as she is very fearful of her
father, Giles R. Denham.” Jean Martin further writes: “In closing I ask …
Why this child is not in protective custody like foster care while you
investigate where she can be safe instead of with her father who seems
to be the one abusing her? Doesn’t Cheyenne have that right?”
M. Brent Johnson, Supervisor of Department of Children and Family Services

in Rockford, Illinois - Has signed off on all the DCFS reports in re: Deborah
Orlando Cooney; Julia Bornhuetter-Colloton; and Rhonda Griffith-Kraut
cases without regards to ensure that the reports are accurate, complete, and
investigated appropriately following the Departments Administrative Rules.
These three (3) Plaintiffs all have Judge Steven L. Nordquist and Kathryn
Bischoff involvement as their Child Representative. Coincidentally, Brent
Johnson contributed financially to Judge Steven L. Nordquist’s election
campaign in 2002. (EXHIBIT #20). Attorney Kosek in Kathryn Bischoff ‘s
office had also financially contributed to Judge Steven L. Nordquist’s
election campaign in 2002. (EXHIBIT #20).
N. David E. Jacobsen – On Sept. 26, 2000, the cause coming before Judge
Steven Nordquist for status, ordered Kathryn Bischoff’s Motion to be filed
instanter, with copies given to counsel in open court, which requested that
Julia is to submit to psychological evaluation and suspension of all
visitations between herself and her children. (GROUP EXHIBIT #21).
Judge Steven Nordquist ordered on 9-26-2000 that Julia Colloton have NO
CONTACT with the minor children until Oct. 13, 2000 during
“compensatory visitation” and to submit to psychological examination by
Lydia Home Assoc. Judge Nordquist further ordered that Julia is not to
accept employment at March School until further order of the court. Set for
14
status on Oct. 13, 2000. See Order attached. (GROUP EXHIBIT #21). Court
transcript of September 26, 2000 demonstrates on page 13, Kathryn
Bischoff requesting a “No Contact order”. On page 15, Attorney Polito
representing Julia Colloton stating: “What is being asked as far as I am
concerned Your Honor is extremely detrimental to my client for
reasons of which, you know, these are conclusions, summaries being
made I have no privy to.” Page 19 of court transcript, Attorney Polito
suggesting that Dr. Sol Rappaport do the psychological testing since he has
already been involved in the case. Page 20 of court transcript Kathryn
Bischoff recommended and insisted to the court that David Jacobsen could
do the psychological testing, and that Dr. Sol Rappaport was not qualified to
do psychological testing of Julia. Transcript attached. (GROUP EXHIBIT
#21).
In a letter dated March 17, 1998 (GROUP EXHIBIT #21) from Kathryn
Bischoff to Attorneys Canfield representing Douglas Colloton, and
Heckinger representing Julia, Kathryn Bischoff wrote: “I am impressed
with the program plan from Neuropych and the amount and
qualifications of the staff of Neuropsych. I feel confident that
Neuropsych can conduct a thorough, as well as objective, custodial
evaluation. It is therefore, my recommendation to the Court on March
24.” Attached is the Custodial Evaluation performed at NEUROPSYCH,
S.C., by Dr. Sol Rappaport, a licensed clinical psychologist dated Oct. 13,
1998. Page 13 recommendation #1 “that sole custody of Kristin and
Natale Colloton be granted to Julia Colloton.” (GROUP EXHIBIT #21).
On Oct. 13, 2000, Judge Steven Nordquist ordered: “that on an interim

basis, care control, custody and education of the minor children is
awarded to the Plaintiff, Douglas Colloton. Julia is to have supervised
visitation”. This order was made on a date set for status not set for a
hearing. See order (GROUP EXHIBIT #21). On Oct. 27, 2000 Judge Steven
Nordquist further ordered: “either party may record the telephone
conversations between the minor children and the Defendant, Julia
Colloton.” See order (GROUP EXHIBIT #21). The order, by Judge Steven
Nordquist is in violation of state and Federal regulations for eavesdropping.
Report by David Jacobsen dated 11-21-2000 with recommendation #1 stated

that: “It is recommended that the court consider a return to the joint
custody agreement previously in place as long as both parents can
cooperate more fully in decision making and the tension can be
reduced.” On Dec. 29, 2000 Michael Raridon, the newly appointed GAL in
Colloton case wrote a letter to Dr. David E. Jacobsen in which Raridon
stated: “I am concerned that her (Julia Colloton) sexual assault history
may provide a significant clue as to the extent of the “shadow”
diagnoses you reference, and that with this additional background
information, you may wish to amplify your report and / or modify your
15
findings and conclusions as well as your recommendations.” (GROUP
EXHIBIT #21).
Dr. David Jacobsen notified on 12/20/2000 by Michael Raridon, GAL, for

Colloton minors, was requested to do an Addendum to his initial report of
11-21-2000. The Addendum report was changed to read as follows: “It is
recommended that Kristin and Natale not be reunified [sic] with Ms.
Colloton.” See addendum attached (GROUP EXHIBIT #21). On January 4,
2001 Michael Raridon sends a letter to Dr. David Jacobsen stating:
“Pursuant to our telephone conversation enclosed you will find a money
order for your services. Thank you for completing the addendum in a
timely manner. We will continue to use your services in the future.” See
letter (GROUP EXHIBIT #21). Query: Why would Attorney Michael
Raridon pay for an Addendum completed, at his request of Dr. David
Jacobsen, with a money order and not with a check from his (Raridon’s) law
firm?
Illinois Department of Professional Regulations (IDPR) on April 6, 2004

ordered Dr. David Jacobsen to CEASE AND DESIST. IDPR found that:
“Respondent (David Jacobsen) is presently unlicensed to practice
Clinical Psychology in the State of Illinois and has never held a
Certificate of Registration as a Clinical Psychologist in the state of
Illinois”. Further found: “During the period of in or about November
2000 through Jan. 9, 2001, Respondent (David Jacobsen) acted in the
capacity of a Clinical Psychologist, including but limited to, preparing a
Psychological evaluation: Parental Competency and Addendum
regarding J.C. (Julia Colloton) pursuant to a custody dispute in a
dissolution of marriage proceeding. As a result of Respondent’s
unlicensed practice, J.C. (Julia Colloton) lost custody of her children.”
IDPR order signed by Fernando E. Grillo on Feb. 25, 2004. See Order
attached (GROUP EXHIBIT #21). On September 26, 2000 Kathryn
Bischoff insisted on David Jacobsen completing the court ordered
psychological testing of Julia and she (Bischoff) stated that David Jacobsen
was qualified to do such testing. See transcript. (GROUP EXHIBIT #21).
O. Rockford Public Schools - Kristin Schroeder, Cheyenne's special education

teacher at Spring Creek Elementary School engaged in very questionable
behavior with the father of Cheyenne over a period of a few years leading
up to the emergency OOP of 9-1-04 being issued. The two communicated
almost daily by phone, fax, and emails including after school, on weekends,
and during summer vacation concerning the custody proceedings, often
denigrating Rhonda and Cheyenne.
On March 27, 2003 at 2025 (8:25 p.m.), an e-mail from Giles Denham to
Kristin Schroeder wherein Giles wrote: “Before the court appointed an
attorney for Cheyenne, Cheyenne would defend me against her
16
mother’s accusations. Rhonda would accuse me of things that were not
true to anyone that would listen to her, weather [sic] Cheyenne was
there or not. There is a severe case of P.A.S. (Parental Alienation
Syndrome) going on here.” (GROUP EXHIBIT #28).
On Sept. 22, 2003 at 7:16 a.m., an e-mail from Giles Denham to Kristin
Schroeder wherein Giles wrote: “Saturday morning at the breakfast table
Cheyenne had a real bad smart mouth. I told her if she keeps it up, I am
going to give it back to her, she kept on. ……….. I warned her that if
she does not watch her mouth, I was going to pop her one. Cheyenne
challenged me again! I popped her one in the back of the head with my
fingertips only, not anything really but something to make her think
about it.” (GROUP EXHIBIT #28). Kristin Schroeder did not report this to
the Department of Family and Children Services. A mandated reporter who
neglects to report to Department of Children and Family Services suspected
instances of child abuse or neglect has committed a Class A misdemeanor.
On Jan. 12, 2004 at 4:21 p.m., an e-mail from Kristin Schroeder to Giles
Denham wherein Kristin wrote: “Report cards are coming out next week.
I think that should be enough to show the people you need to show. All
we can attest to is the improvement she has made this semester. We can
not truly say the reason because that would be very hard to prove.”
Giles Denham responded back to Kristin Schroeder and wrote: “I really
need your help to try to get Cheyenne out from under Rhonda messed
up control!” Giles further wrote: “I have not been running around
asking people for help, but know I have too, Rhonda has been doing all
she can to get her “Cash Cow” back.” (GROUP EXHIBIT #27).
On Jan. 27, 2004 at 4:13 p.m., an e-mail from Giles Denham to Kristin
Schroeder wherein Giles wrote: “2) Obviously need to show Kathryn
Bischoff (Cheyenne’s Rep) what is going here.” (GROUP EXHIBIT #27).
Schroeder allegedly made a false report to the D.C.F.S. hotline on 8-27-04

stating that Rhonda Griffith-Kraut had somehow been physically abusive of
Cheyenne because Schroeder was upset that D.C.F.S. had been called on
Giles Denham and made a promise to Giles in an email that she would
watch his back after he'd again hit Cheyenne. After Rhonda was found to be
innocent by a DCFS.’ ALJ Gary Golian (GROUP EXHIBIT #29), Kristin
Schroeder decided to help Giles Denham and Kathryn Bischoff cover up the
wrongdoing committed on 8-27-04, whose actions prompted investigations
by police and D.C.F.S. Schroeder decided to continue to resurrect the false
report by repeating the lie in a plenary OOP hearing on 7-28-05. Any person
who knowingly transmits a false report to the Department of Children and
Family Services commits the offense of disorderly conduct under subsection
(a)(7) of Section 26-1 of the Criminal Code of 1961. A violation of this
subsection is a Class A misdemeanor.
17
On Mar. 23, 2005, report of an incident at 9 a.m. about Cheyenne Griffith
and her teacher, Mrs. K. Schroeder. Administrator, Lynell Kenny’s wrote:
“Father picked Cheyenne up, talked with staff, and took her in the
bathroom for a talk. I stood in doorway to listen and monitor. He talked
with her calmly, I heard 2 swats with his hand.” (GROUP EXHIBIT
#28) Administrator, Lynell Kenny did not report this incident to the
Department of Children and Family Services. A mandated reporter who
neglects to report to Department of Children and Family Services suspected
instances of child abuse or neglect has committed a Class A misdemeanor.
On June 6, 2006, Rhonda wrote a letter to Lynell Kenny, Principal, at Spring

Creek School, wherein Rhonda wrote: “Cheyenne has an annual I.E.P.
due to her status as learning disabled and having her A.D.H.D. I have
not been invited to attend for the last two years. This year I was not
invited to attend nor was I provided a copy of her I.E.P.” (GROUP
EXHIBIT #28).
On Nov. 1, 2006, Rhonda wrote a letter to Mrs. Greenburg at Spring Creek

School, wherein Rhoda wrote: “I am Cheyenne Griffith’s mother. I
would like to request a conference with you to discuss her
performance.” (GROUP EXHIBIT #28).
On Nov. 10, 2006 Rhonda wrote a letter to Mrs. Greenburg at Spring Creek
School, wherein Rhonda wrote: “I am following up on a letter and a
phone call that I made to request a date/time for a conference to discuss
my child, Cheyenne Griffith’s progress in your class & Spring Creek
School. To date I have not received an appointment per my request.
…… I have had no communication from the school since June 2006
despite my request to be kept informed of Cheyenne’s progress.”
On Feb. 16, 2007 Plaintiff, Rhonda, Stanley Kaplan, wrote a letter to Mr.
Katz, Attorney with Rockford Public Schools wherein he stated: “As I
understand the proceedings thus far, there had an order of protection
entered, and that order expired and is no longer in full force and effect.
There is no court order restricting her access to Cheyenne, either at school
or otherwise. According to 750 ILCS 5/607, unless there is a petition
alleging serious endangerment to the child’s emotional, mental, physical or
moral well-being, there can not be any restriction on visitation. There must
be a hearing before there can be any restrictions. There is no pleading on
file; there is no order of restriction; yet the school authorities at Spring
Creek School, predicated upon the father’s statements, refused access to the
mother.” (GROUP EXHIBIT #28).
18
On April 8, 2007, Jean Martin, wrote a letter to Attorney Steven Katz with
the Rockford Public Schools, wherein Jean stated: “On 2-14-07, I
accompanied Rhonda to Spring Creek School to observe Cheyenne’s
valentine activities and deliver her gifts. The Principal, Lynell Kenny,
refused to allow Rhonda to see or to speak with her child, Cheyenne.
The secretary told us not to sign in. We had already done so though.
Kinney told us we could not “visit” with Cheyenne because the father
Giles who was contacted by Deb Kipner, “objected”. Kinney said that
her records show that “Rhonda has only court ordered supervised
visitation and that Giles has physical custody.” Rhonda asked to see
documentation. Kinney produced an order of protection that Rhonda
noted was expired by 12 ½ months. This was the only documentation
offered.” (GROUP EXHIBIT #28).
FACTS RELATING TO THE NAMED PLAINTIFF, DEBORAH

ORLANDO COONEY:
1. The Plaintiff, Deborah, named herein was involved in a post judgment

matrimonial matter which commenced when she filed a motion to remove the
children to the State of Ohio filed on Oct. 19, 2001(GROUP EXHIBIT #22).
Plaintiff’s former husband, Lorenzo Orlando, then filed a petition for change of
custody filed on Nov. 9, 2001 (GROUP EXHIBIT #22). Judge Steven Nordquist
denied Plaintiff, Deborah’s Petition for removal in a Memorandum of Decision
dated Aug. 15, 2002 and Court Ordered signed on Aug. 29, 2002. (GROUP
EXHIBIT #22) Judge Steven Nordquist took almost ten (10) months to answer.
2. After numerous court appearances, Judge Steven Nordquist, after having

appointed Kathryn Bischoff as Child Representative (EXHIBIT #6) began his
course of conduct of violating the various Constitutional rights of the Plaintiff,
Deborah.
3. On June 14, 2005, in violation of the 1st amendment, Judge Steven Nordquist
entered what is commonly known as a “gag” order. That order is attached and
marked (EXHIBIT #11). Notwithstanding the said order, the former husband,
Lorenzo Orlando, had signed a petition for order of protection (not for an
emergency order of protection) (GROUP EXHIBIT #4) and a petition for transfer
of custody (GROUP EXHIBIT #3). This pleading had direct quotes from
defendant, Dr. Rossiter’s unsigned opinionated draft report and was notarized on
June 13, 2005, two (2) days before the parties had allegedly received the report of
Defendant, Dr. Rossiter, and one (1) day prior to the “gag” order of June 14,
2005. Either Dr. Rossiter or Kathryn Bischoff, or both, had surreptitiously
delivered a copy of the report to either Lorenzo Orlando or his attorney, Daniel
Cain. On June 15, 2005, without notice to the named Plaintiff, Deborah, without
a hearing, and based solely on Dr. Rossiter’s unsigned draft report, an order was
19
entered immediately transferring custody of the children along with a no contact
provision; an emergency order of protection was entered claiming among other
things that the Plaintiff, Deborah, was armed and suicidal. (GROUP EXHIBIT
#4). There was never a finding or claim in Dr. Rossiter’s draft unsigned report
that anyone was suicidal or armed. The pleadings before Judge Steven Nordquist
were deficient according to the Domestic Violence Act and 750 ILCS 5/602.
Neither claim was accurate, yet the Defendant, Judge Steven Nordquist, in
violation of the Plaintiff’s 14th amendment rights and in total violation of
750ILCS 5/605, and in violation of 750 ILCS 5/607(a) which states: “a parent not
granted custody of the child is entitled to reasonable visitation rights unless the
Court finds, after a HEARING, that visit would endanger seriously the child’s
physical, mental, moral, or emotional health.”, deprived the Plaintiff, Deborah, of
her rights to custody of the children and as a result thereof, irreparable harm was
done to the mother-child relationship. See transcripts of June 15, 2005. (EXHIBIT
#5).
4. Thereafter, there were a series of court orders entered by Defendant, Judge Steven
Nordquist extending the “21” day emergency order of protection for a period of
22 days and then 55 days. That Judge Steven Nordquist even had an extension of
the order of protection entered by U.S. mail, with no notice to the Plaintiff,
Deborah or her counsel or any other party to this case. In addition, to the
foregoing notations were made on the court docket sheet as a result of court
orders entered by Judge Steven Nordquist stating that Plaintiff and her counsel
were present and argued against the extension-one time when Deborah was at
work in Highland Park, Illinois and her counsel was in Arizona; the other
occasion, was when Deborah’s attorney was attending the funeral of his cousin.
Attached are all court orders extending the initial exparte order of protection of
June 15, 2005, given to Plaintiff Deborah, by Judge Steven Nordquist. See all
Orders. (GROUP EXHIBIT #23). On Dec. 12, 2006 Judge Brian D. Shore
vacated the ex parte order of protection and dismissed the petition of 6-15-05.
5. As a result of Judge Steven Nordquist’s orders of June 15, 2005, Plaintiff,

Deborah’s counsel filed on July 5, 2005 a Petition for Rehearing,
Reconsideration, or in the Alternative New Trial and for Other Relief. Petition
was not heard until Sept. 22, 2005 and was denied by Judge Steven Nordquist
(GROUP EXHIBIT #27). Plaintiff, Deborah, filed on Sept. 14, 2005 Motion to
Vacate Order of Protection which was denied by Judge Truitt. (GROUP
EXHIBIT #27). Plaintiff, Deborah filed on Sept. 30, 2005 Motion to Strike
Petition for Order of Protection and Dismiss Pending Emergency Order of
Protection which was denied by Judge John Truitt. (GROUP EXHIBIT #27).
Plaintiff, Deborah filed on Oct. 18, 2005 a Motion to Accelerate Hearing on
Motion to Vacate Order of Protection / Dismiss Order of Protection which was
denied by Judge Truitt. (GROUP EXHIBIT #27). Plaintiff, Deborah filed on Nov.
21, 2005 a Motion to Vacate Emergency Order of Protection which was denied by
Judge Truitt. (GROUP EXHIBIT #27). Plaintiff, Deborah filed on Dec. 1, 2005
an Emergency Motion to Set Holiday and Ordinary Visitation, Judge Truitt did
20
not rule on the emergency motion, and to date said Motion is still pending.
6. A factual list of the continuing violations of Judge Steven Nordquist, including

his voluntary recusal from the case on Sept. 1, 2005 (GROUP EXHIBIT #23), the
case is then transferred to Judge John Truitt, and then on July 3, 2006 Judge
Steven Nordquist’s re-entered as trial judge, again violating the Constitutional
rights of the Plaintiff. See Administrative Order (GROUP EXHIBIT #24).
Plaintiff, Deborah’s counsel, David Mokotoff, had filed on July 19, 2006 a
Petition for Substitution of Judge, a Petition of Substitution of Judge for Cause
with a Memorandum in support of Petitions, attached. (GROUP EXHIBIT #24).
Judge Janet Holmgren granted the Petition for Substitution of Judge and
Deborah’s case was transferred to Judge Brian D. Shore. See Order (GROUP
EXHIBIT #24).
7. Plaintiff, Deborah obtained an Emergency Order of Protection on behalf of minor,

Christopher Orlando on June 4, 2004, in Cook County, against his father, Lorenzo
Orlando due to phone threats that frightened Christopher Orlando. (GROUP
EXHIBIT #40). Case was reset for hearing on July 1, 2004, see Cook County
Order. (GROUP EXHIBIT #40) Order transferring case to Winnebago County on
7-1-04 (GROUP EXHIBIT #40) Lorenzo Orlando violated the Order of
Protection twice, first with a threatening e-mail to Christopher and secondly with
harassing telephone calls while a phone trap was on the line. Cook County placed
2 bail bonds out for Lorenzo Orlando, one for $5000.00 and the other for
$50,000.00. Judge Steven Nordquist was aware that Lorenzo Orlando violated the
Cook County Order of Protection and Judge Steven Nordquist proceeded to
vacate the Order of Protection on July 9, 2004. (GROUP EXHIBIT #40). Judge
Steven Nordquist further ordered the reduction of the Cook County bail bonds
from $55,000.00 down to $2000.00. See Order. (GROUP EXHIBIT #40). Lastly,
Judge Steven Nordquist ordered on July 7, 2004 the following: “In the event that
any court action or pleading is filed by the petitioner or on behalf of the
parties minor children which affects the rights of the respondent, Lorenzo
Orlando, it must be filed only in Winnebago County, Illinois until a court
order to the contrary is signed by a Judge of the 17th Judicial Circuit,
Illinois”. (GROUP EXHIBIT #40). Plaintiff, Deborah, with the minors resided in
Cook County since 1996 until current. This is in violation of 750 ILCS 60/209(a)
(i)(iii).
8. On May 11, 1998, Plaintiff, Deborah’s counsel Allyson Misevich wrote a letter to
Mr. Marc Gasparini, Winnebago County Circuit Clerk which stated: “On Friday,
May 8, 1998, I went to the Divorce Division to review the court file of the
Orlando case which is a large file that was supposed to contain six (6)
volumes. I noted that one of the volumes listed as Volume 4 was missing, the
clerk could not find it, and I was unable to review that volume on behalf of
my client. I requested to the clerk that a search be initiated and to contact my
office immediately upon finding Volume 4 of the Orlando file. Please also
21
note that Judge Nordquist did not have the entire file available for his review
during the last court proceeding (a trial) in March 1998, and he requested
that the clerk find this file immediately at that time.” (GROUP EXHIBIT
#30).
9. On Sept. 14, 2005 Plaintiff, Deborah, obtained a copy of her Court docket sheet
and had each page certified when she (Cooney) had noted erroneous entries, see
certified copy of docket from 5-3-2005 to 9-7-2005 (GROUP EXHIBIT #30).
On Sept. 29, 2005 Plaintiff Deborah’s mother, Rose Wietrzykowski wrote a letter
to Chief Justice Kathryn Zenoff, wherein Rose Wietrzykowski wrote: “for
example an entry in docket sheet on 9/2/2005 which reads EMERGENCY
ORDER OF PROTECTION IS CONTD UNTIL 9/22/05 AT 11 AM. JUDGE
TRUITT TO HOLD HEARING. PARTIES SERVED IN OPEN COURT”.
SEE ORDER. The fact is that Judge Steven Nordquist mailed the extension of the
Order Protection which was dated Sept. 2, 2005 enclosed with a letter dated Sept.
1, 2005 to Plaintiff’s Attorney, Stanley Kaplan’s office in Northbrook, IL, that he
received on Sept. 2, 2005. Query: How could Attorney Stanley Kaplan received
an order dated Sept.2, 2005 from Winnebago County in his office in Northbrook
on Sept. 2, 2005? There never was any court on 9-2-2005 therefore Plaintiff,
Deborah was never served in OPEN court this extension of order of protection.
There were no notices to any counsel involved in re: the Marriage of Deborah
Orlando vs. Lorenzo Orlando. Service was done via U.S. mail, and there was no
hearing. There are numerous other erroneous entries in the docket sheet which
could not be explained by Tom Kline, Winnebago County Circuit Clerk, nor Todd
Schroeder, Winnebago County Trial Court Administrator. (GROUP EXHIBIT
#30).
On Oct. 3, 2005, Todd Schroeder, Trial Court Administrator in Winnebago

County wrote a letter to Rose Wietrzykowski, wherein Schroeder wrote: “The
Chief Judge and myself are both in receipt of your letter dated Sept. 29, 2005
regarding Case No. 93-D-1332. Unfortunately, we are both going to be out-
of-the-office for much of this week on court related business, and will not
have the time to look into the issues you raise until after this week”. (GROUP
EXHIBIT #30).
On Oct. 18, 2005, Plaintiff Deborah’s counsel, Stanley Kaplan filed a Motion to
Correct Inaccuracies / Misrepresentations in the Court Docket Sheet. Motion was
NEVER heard even though Attorney Stanley Kaplan noticed this Motion for Nov.
29, 2005. (GROUP EXHIBIT #30).
On Nov. 21, 2005, Plaintiff, Deborah, checked her docket sheet and obtains a
print out for dates 6-13-2005 to 11-17-2005. Plaintiff realized the number of
changes that were being done to her (Deborah’s) docket sheet without having a
hearing on Motion to Correct Inaccuracies / Misrepresentations in the Court
Docket Sheet. (GROUP EXHIBIT #30). All changes to Deborah’s docket sheet
22
were based upon her (Deborah’s) Petition to correct inaccuracies /
misrepresentations in said docket sheet.
On Feb. 3, 2006, Todd Schroeder, Trial Court Administrator wrote a letter to

Rose Wietrzykowski, Plaintiff Deborah’s mother, and stated: “As for the entries
of 7/20 and 8/4 that you referred to, I have no explanation as to why these
entries indicated erroneous information, but can only indicate that the
Appeal’s Clerk has corrected these entries to reflect events which seem more
concurrent with your recollection or description of events. The entry of 8/23
you refer to was entered from a “blue Sheet”, which is a document prepared
by the Judge regarding events occurring in court when no clerk is present. I
have no explanation of why the Blue Sheet entry differs from your version of
events that day. The Order your attorney received on September 2nd signed
and dated by Judge More as having occurred on September 2nd did in fact
occur in the morning of September 1st. When the fax from Judge Nordquist,
that indicated reassignment of the case to Judge Truitt. The fact that this
Order was signed on September 1st and placed in the mail with a copy of
Judge Nordquist’s letter attached explains why both documents were
received by Mr. Kaplan’s office on September 2nd. I can offer no explanation
for the entry indication that the parties were in Court and served with the
Order on that date.” (GROUP EXHIBIT #30).
10. On March 17, 2006, Plaintiff, Deborah’s counsel, David Mokotoff filed a Petition
to Remove Child Representative, Kathryn Bischoff, and asked for a hearing
thereon instanter. (GROUP EXHIBIT #31). The Petition To Remove Child
Representative, Kathryn Bischoff alleged numerous actions / behaviors that one
would deem to be inappropriate and gave the appearance of impropriety. On April
13, 2006 Kathryn Bischoff filed her response to Petition to Remove Child
Representative (GROUP EXHIBIT #31). It was not until Dec. 19, 2006, nine (9)
months later, at the commencement of the hearing in front of Judge Brian D.
Shore, just minutes prior to calling Kathryn Bischoff as a witness to give
testimony in the Orlando case, that she opted to voluntarily withdraw. See court
order dated Dec. 19, 2006 (GROUP EXHIBIT #31). Later in the afternoon of
Dec. 19, 2006 in front of presiding Judge Janet Holmgren for a Chancery suit
against Kathryn Bischoff, Judge Holmgren ordered that Kathryn Bischoff shall be
required to attend hearing and produce documents pursuant to the subpoena. See
court order (GROUP EXHIBIT #31).
11. On Dec. 19, 2006, Judge Shore ordered that “Judge Truitt to assign a new
Child Representative”. Plaintiff, Deborah’s case is being heard in Boone County
instead of Winnebago County, where it was filed in 1993. On Jan. 4, 2007 with
presiding Judge John Truitt an issue of a fair and timely trial in Court arose. On
Jan. 11, 2007 Plaintiff, Deborah, had filed a Petition for Change of Venue
(GROUP EXHIBIT #25) and Judge Truitt’s order denying a Change of Venue,
attached. (GROUP EXHIBIT #25).
23
12. On April 23, 2007, in front of presiding Judge John Truitt, Plaintiff Deborah’s
counsel David Mokotoff, had noticed a Motion in Limine and a Motion for
Rehearing and Reconsideration and for other Relief. Attorney for Plaintiff
Deborah, David Mokotoff stated: “My question to the Court is even if I’m
going to be denied my motion for rehearing, reconsideration and other relief,
am I not under the Constitution of the United States of America entitled to a
hearing?” Judge Truitt stated: “I have ruled on the motion that was before the
court. You received it in the mail. That’s all for today. Thank you.” Attorney
David Mokotoff stated: “Judge, could you explain to me how you can rule on a
motion for rehearing through the mail before it’s even filed? Would you just
let the record reflect, also, that Judge Truitt has removed himself from the
bench and that I’m talking to myself. Thank you.” This is an example of a
blatant disregard of Plaintiff, Deborah’s due process rights and the 14th
Amendment of the United States Constitution. See court transcript. (GROUP
EXHIBIT #25).
13. As a result of the actions of Dr. Rossiter (605 evaluator), Kathryn Bischoff (Child
Representative), Judge Steven Nordquist, Daniel Cain (counsel for Lorenzo
Orlando) and Brian Klaung (therapist for Orlando minors), the Plaintiff, Deborah,
has not had any contact with her two sons, Christopher and Jonathan Orlando,
since June 15, 2005, the day Christopher was removed from court in handcuffs by
members of the Rockford Detective Agency and transported to the Swedish
American Hospital in Rockford, Illinois without a court order. (EXHIBIT #26).
14. On Oct. 30, 2003 Plaintiff, Deborah, filed for an Emergency Order of Protection
on behalf of Christopher Orlando as suggested by Rockford Police Officer, Dan
Marino, against his father, Lorenzo Orlando. Judge Steven Nordquist refused to
give Christopher an Emergency Order of Protection and stated: “All parties have
to be present in court”. Judge Nordquist set a date for Nov. 16, 2003 at which
time the Respondent, Lorenzo Orlando and his counsel, Dan Cain, did not appear
in court. Judge Steven Nordquist would not rule on the Petition for Emergency
Order of Protection and thus it remains unheard to date. (GROUP EXHIBIT #41)
Along with the Petition for Emergency Order of Protection, a Petition for
Supervised Visitation was filed on Oct. 30, 2003, and to date still has not been
heard. (GROUP EXHIBIT #41).
Petition for Relief of Judgement was filed on 8-29-02 with Judge Steven
Nordquist presiding, in which the allegation is that Plaintiff, Deborah’s ex-
husband, Lorenzo Orlando committed fraud and perjury during the financial
portion of the divorce. (GROUP EXHIBIT #41). Amended Petition for Relief of
Judgement filed on 10-9-02 still not heard. (GROUP EXHIBIT #41)
Plaintiff, Deborah, filed on 5-11-05 Petition for Rule to Show Cause in front of
presiding Judge Steven Nordquist, which remains unheard to date. (GROUP
EXHIBIT #41). This Petition deals with a large sum of money owed to Plaintiff,
24
Deborah, by respondent, Lorenzo Orlando which in fact Judge Steven Nordquist
previously ordered Lorenzo to pay these monies.
On Oct. 18, 2005, Plaintiff, Deborah’s counsel, Stanley Kaplan, filed Motion to
Set Hearing in front of presiding Judge John Truitt. Noticed for Nov. 29, 2005.
This motion has never been heard. (GROUP EXHIBIT #41).
FACTS RELATING TO THE NAMED PLAINTIFF, JULIA

BORNHUETTER-COLLOTON:
1. That on October 10, 1997, the Defendant, Paul Logli, Winnebago County State’s
Attorney, at the behest of Julia’s husband, Douglas and Father Eric Barr,
orchestrated an involuntary commitment at H. Douglas Singer Mental Heath
Center (GROUP EXHIBIT #15). That thereinafter, Paul Logli penned a letter
threatening to arrest Julia despite an existing OOP against Douglas Colloton
(GROUP EXHIBIT #15). To compound matters more, Chief Judge Zenoff, after
finding Julia to have been abused by Douglas Colloton on 11/26/97, entered a
three year plenary OOP (or until duration of the divorce, whichever was greater)
against Douglas Colloton on December 19, 1997. (GROUP EXHIBIT #13 ).
2. Kathryn Bischoff then entered the picture and pushed for a Neuropsych
evaluation using Dr. Sol Rappaport. Dr. Rappaport’s report dated Oct. 13, 1998
recommended sole care, custody, control and education to be with the mother,
Julia Bornhuetter-Colloton. The report found Julia to be psychologically sound.
3. On Sept. 26, 2000, without a hearing, Judge Steven Nordquist entered a

“Temporary-Interim” order transferring custody to Douglas Colloton, the
father. This was during the time the father had allegedly molested Natale, the
minor daughter, almost 8. There was no notice of the hearing, no notice of
motion being filed, only an order. (GROUP EXHIBIT #21). The temporary order
transferring custody of Colloton minors still exists for 7 years.
4. On September 15, 2000, Kathryn Bischoff and John Budzinski began their actions
to make sure that Julia Colloton never got her children back. This is evidenced by
the paper trail based upon letters between the two aforementioned defendants.
See (GROUP EXHIBIT #13).
5. On September 26, 2000, Kathryn Bischoff filed a motion to remove the children
from Julia Colloton and Judge Steven Nordquist enter an order requiring a SCR
215 psychological examination by David Jacobsen of Lydia Home, along with, no
contact with the children aged almost 8 and 10. (GROUP EXHIBIT #21). The
motion was filed instanter, the matter which was set for status resulted, without
notice to Julia Colloton, to a hearing and an order entered on October 13, 2000,
granting custody on an interim basis to Douglas Colloton. That interim, temporary
25
order is, six and a half (6 ½) years later, still in existence with the Plaintiff, Julia
being refused proper access to the courts and to her children. (GROUP EXHIBIT
#21). Judge Steven Nordquist also entered an order which violated Federal USC
Title 18 2510-2515, wire tapping statutes, that permitted Douglas Colloton to tape
record Julia and the children without their knowledge or consent (GROUP
EXHIBIT #21).
6. That David Jacobsen had misrepresented himself, as a psychologist, when he was

never licensed in Illinois. The Illinois Dept. of Professional Regulation /
Certification issued a Rule to Show Cause and a Cease and Desist order against
David Jacobsen. It was adjudicated, by the State of Illinois, that Julia Colloton
had lost custody of her children due to David Jacobsen’s’ addendum report, in
spite of the fact that he held no license. (GROUP EXHIBIT #21).
7. That (GROUP EXHIBIT #21) consists of the first parental evaluation by David
Jacobsen stating that Julia was not brainwashing the children in a negative manner
and also suggested joint custody with Douglas Colloton being the residential
parent. That Michael Raridon, newly appointed Child Representative, sent a letter
to Jacobsen wanting him to review and rewrite a new addendum. Somehow it
appears that money passed hands from Michael Raridon to David Jacobsen via a
money order for the addendum. Upon information and belief the money order was
in the amount of $1,500.00.
8. Plaintiff, Julia’s counsel, Chester Chostner, Amended Motion to Vacate or

Modify Order of Oct. 13, 2000 was filed on or about Sept. 2001, stating that the
orders of Oct. 13, 2000 violated Julia Colloton’s due process and constitutional
rights. He further stated: The Court’s decision on Oct. 13, 2000 was based on
incompetent testimony of John Budzynski, with lack of credentials, and Chostner
further stated: “who subscribe to an aberrant psychiatric ideology commonly
referred to as Parental Alienation Syndrome (PAS). PAS is unproven and
cannot pass the Frye “plus” standard for acceptance of scientific evidence
adopted by the State of Illinois.” Chostner further stated: “The ruling of this
Court of Oct. 13, 2000 violates a fundamental constitutional right of Julia
Bornhuetter under the Fourteenth Amendment to the United States
Constitution.” See Motion (GROUP EXHIBIT #33). Nov. 7, 2001 Judge Steven
Nordquist gave a Memorandum of Decision and Order that Motion of Sept. 2001
to Amend Vacate or Modify Order of Oct. 13, 2000 wherein Judge Nordquist
wrote: “Defendants’ former counsel waived the due process objections by
going forward at the hearing on Oct. 13, 2000”. Motion was DENIED by Judge
Steven Nordquist. (GROUP EXHIBIT #33).
9. On October 28, 1998, Paul A. Logli, in conjunction with Kathryn Bischoff and
John Budzynski sent letters concerning the halting of both Natale and Kristin
from testifying in the Domestic Violence Trial against Douglas Colloton (GROUP
EXHIBIT #13). They were the only witnesses of Douglas’ violence, therefore
Julia could not prove her case.
26
10. A bizarre order was entered on October 23, 2001, which states that Julia Colloton
should have NO VISUAL CONTACT with the minor children, Kristin and
Natale, without approval from Mick (Supervisor of visitation), Judge Steven
Nordquist, Michael Raridon (Child Representative for Colloton minors), Robert
Canfield (counsel for Douglas Colloton), John Budzynski (therapist for Colloton
minors and Douglas Colloton) and Douglas Colloton’s approval. (GROUP
EXHIBIT #33).
11. On October 13, 2000, John Budzynski, a surprise witness, testified that Julia
should not have her children back. This recommendation was in spite of the fact
that John Budzynski had never even met Julia up to that time nor has he met her
to date: 9 years later. (GROUP EXHIBIT #13)
12. John Budzynski filed the charges through the Roscoe, Illinois Police Department.
Julia is currently attempting to show that the charges should be dismissed using
the Brady Doctrine, to show that the grand jury was lied to by the State’s
Attorney’s office / John Budzynski and the charge was predicated upon a false
police report by John Budzynski. (GROUP EXHIBIT #16).
13. On October 23, 1997, notwithstanding documented domestic violence (GROUP

EXHIBIT #13), Chief Judge Zenoff entered an order mandating that the couple
reside together which led to Julia being further abused and suffered severe nerve
damage at the hands of Douglas Colloton to Julia Colloton’s back and right side
of her body (GROUP EXHIBIT #13).
14. That on September 23, 2003, Julia Colloton appeared in court Sui Juris. She
(Julia) had filed a motion to have the custodial modification declared Void Ab
Initio due to the Constitutional Violations listed therein. (GROUP EXHIBIT #21).
Julia also attempted on that day, to bring in Rockford Police Officer, Basile, who
made sure the minor child Natale was seen for suicidal ideation. Judge Steven
Nordquist refused to see or hear any of the evidence, and excused Rockford
Police Officer, Basile.
15. Most Recently, Judge Steven Nordquist is denying Julia a trial for her children,
refuses to allow her additional or any time with her children. The recent court
order on December 22, 2006, gave Michael (Mick) Hanson (Julia’s court
appointed supervisor of visitation) ultimate power. Judge Steven Nordquist did
grant Julia “’UNSUPERVISED” Visitation with her daughters on Christmas Day
from 9 am until 3pm; and from 3pm until 9 pm, Julia had to be supervised. This
is a clear abuse of judicial discretion, and under the Rules of Professional Conduct
of the Illinois Code of Judicial Conduct. (GROUP EXHIBIT #34).
16. Julia fired Michael Hanson due to harassment on the night of January 25, 2007.
Michael Hanson still continues to show up at Julia’s residence with Douglas
Colloton. They no longer bring the children. Judge Steven Nordquist stated that if
27
Julia Colloton wanted to see her daughters now 14 and 16 ½, that she would have
to allow Michael Hanson in her home.
17. On Dec. 6, 2006 and on Jan. 25, 2007 Julia called the Rockford Police because of
problems with Mick (Michael Hansen) providing supervised visitation in Julia’s
home. Rockford Police Officer, P. Marko and partner arrived at Julia’s residence,
and refused to take a report. Rockford Police Officer P. Marko disclosed to Julia
that he was the son-in-law to Judge Steven Nordquist.
FACTS RELATING TO NAMED PLAINTIFF, RHONDA

GRIFFITH-KRAUT:
1. While the Plaintiff, Rhonda was at Centegra Hospital in Woodstock, Illinois, on

September 1, 2004, along with seven other persons including the minor’s pastor,
all eight persons, including Plaintiff, Rhonda, were denied access to the minor,
Cheyenne Griffith, see Centegra notes. (GROUP EXHIBIT #35). This denial was
predicated upon an order of protection entered without notice to the Plaintiff,
Rhonda. Said Order was signed by Judge Nordquist on Sept. 1, 2004 at 4:23 p.m,
transferring custody of minor, Cheyenne to the father, Giles Denham. (GROUP
EXHIBIT #35). The hospital denied access without having a copy of the order of
protection transferring custody to the father. Security people from the hospital
escorted all parties off the premises even though they had not seen the order and
had no knowledge of whom the named persons were on the order relating to no
contact with the child. The order expired on April 11, 2005 and during the time
the order was in place, the Plaintiff, Rhonda and the minor child, Cheyenne, were
denied access to one another. There was no trial until June 22, 2005 and on July
28, 2005; said date being two (2) months after the Emergency Order of Protection
had expired. Judge Steven Nordquist held a hearing that clearly violated the
Plaintiff’s Constitutional Rights of Due Process and the 14th Amendment of the
United States Constitution, and issued a Plenary Order.
2. On Sept. 1, 2004 at 4:23 p.m., Judge Steven Nordquist signed an Ex parte Order
of Protection for Giles Denham against Rhonda and set a hearing on 9-16-04 (16
days) later.
All of the extensions of Ex parte Order of Protection (GROUP EXHIBIT #35)

against Plaintiff, Rhonda by Judge Steven Nordquist were:
On 9-16-04, Judge Nordquist extended OOP to 9-30-04 equaling (15 days)

28
On 5-11-05, No extension of OOP given. See Court docket sheet for court date 5-
11-05 it reads as follows: CAUSE WAS TAKEN OFF CALL. CASE REMAINS
WITH JUDGE NORDQUIST. Docket sheet (GROUP EXHIBIT #35)
On 6-22-05, Judge Steven Nordquist proceeded to a plenary hearing, when in fact

the Exparte OOP had lapsed by 43 days. On June 22, 2005 Judge Steven
Nordquist also ordered that “Cheyenne shall remain in the care and possession of
Giles Denham. See Order. (GROUP EXHIBIT #35). Judge Nordquist continued
the Plenary hearing for OOP against Plaintiff, Rhonda to 7-28-05 at which time
Judge Steven Nordquist entered a Plenary OOP against Rhonda to expire 1-28-06
at 11:00 p.m. (GROUP EXHIBIT #35).
3. The Plenary Order also removed custody of the minor, Cheyenne, from Rhonda,
to the father, Giles Denham. (GROUP EXHIBIT #35). Petitioner had called
witnesses by subpoena and the witnesses were in the court house waiting outside
the court room to be called. Nordquist only permitted the school teacher, Kristen
Schroeder, teacher’s aid and DCFS investigator, Debora McKinney to give
testimony. Judge Steven Nordquist ordered on 6-11-04 that subpoena for Trooper
William Heintz is hereby quashed and his testimony is barred. Trooper Heintz
was in the courthouse waiting to give testimony (GROUP EXHIBIT #35) Judge
Nordquist ordered on 6-8-04 that subpoena for testimony of James Viggiano
Ph.D. was quashed. (GROUP EXHIBIT #35).
The incident Rhonda was being tried for had already been adjudicated by DCFS’
ALJ Gary Golian, who had ruled in her favor and that she was innocent of any
wrong doing (GROUP EXHIBIT #29). The school teacher, Kristen Schroeder, of
Spring Creek School, had been found to have made a false report against Rhonda
accusing Rhonda of Physical Abuse of her daughter, Cheyenne. The trial violated
the Plaintiff, Rhonda’s rights of due process since there had already been an
adjudication and the ruling was res judicata and could not be brought again.
DCFS could have appealed the finding by the ALJ by simply filing an action in
chancery pursuant to statute to have a court of competent jurisdiction conduct a
hearing. See Administrative Rule 336.220(b) Administrative Review Law 735
ILCS 5/Art. III. Instead, DCFS along with the witnesses were permitted to put on
a mock trial and have Judge Steven Nordquist, again make rulings that were
Constitutionally impermissible.
4. DCFS opened a case against the Plaintiff, Rhonda, on or about December 1, 2004.
This was done in spite of the fact that an Assistant Attorney General from
Attorney General Lisa Madigan’s office filed a motion which objected to the
opening of the DCFS case and that the DCFS ALJ found Rhonda innocent.
5. Defendant Kathryn Bischoff and counsel for Giles Denham, Cheri Greenlee
allegedly harassed, intimidated and influenced the Plaintiff, Rhonda’s witnesses.
Two of Cheyenne’s counselors, Redders and Viggiano, as well as one or more of
29
the minor’s day care providers advised the Plaintiff, Rhonda of this conduct.
Letter from Cheri Greenlee to Jamie Redders on April 8, 2004 wherein Greenlee
stated: “If you speak with Cheyenne’s teachers and school nurse, you will
learn that it is Mr. Denham who is the stabilizing influence on this daughter.
…… I know that you are the individual who called the DCFS hotline. I sat in
on the interview with Giles; it was clear that the investigator was leaning
towards a finding of “unfounded”. (GROUP EXHIBIT #36).
On Feb. 10, 2003 James Viggiano, Ph.D. wrote a letter and copied Kathryn
Bischoff and Cheri Greenlee, Giles’ counsel, wherein Dr. Viggiano wrote:”
Cheyenne continues to be distressed by the fact that her parents are fighting
over her and I have urged all parties involved to bring this custody dispute to
a speedy conclusion for the benefit of Cheyenne’ well being. Cheyenne has
stated that she would like to live with her mother and visit with her father.”
(GROUP EXHIBIT #36). Judge Steven Nordquist would not allow Dr. Viggiano
to testify at hearing on Rhonda’s behalf. (GROUP EXHIBIT #35).
On Oct. 10, 2003 Joan Zarate, babysitter for Cheyenne telefaxed a letter to
Rhonda, wherein Joan wrote: “On or about the 8th of September, I received a
call from Mrs. Greenlee the attorney of Giles Denham. Mrs. Greenlee was
very rude; she accused me of lying and wanted to know my business. Mrs.
Greenlee said she will subpoena me if she had to, if I did not tell her what she
wanted to know.” (GROUP EXHIBIT #36).
On Dec. 2, 2004, Kathryn Bischoff wrote a letter to Ms. Deb McKinney, DCFS,
and requests a copy of the expurgated report only to exclude the reporter not
anyone else. (GROUP EXHIBIT #36).
Counselor Jamie Redders was finally able to testify and notwithstanding the fact
that she testified in June, 2004, when she opined that Cheyenne remain in the sole
care and custody of Rhonda due to her work with Cheyenne, her observations and
the hostile confrontations with the father, Giles Denham. Jamie Redders further
told Judge Steven Nordquist, during the hearing, that she videotaped Cheyenne
talking about the abuse. Dr. Viggiano; State Trooper, William Hientz and others
had either been dismissed as witnesses and had their testimony barred, including a
video by the state trooper during a 2001 weapons arrest of Giles Denham, the
alleged father of Cheyenne Renee` Griffith. This was taped by the Illinois State
Police/ATF. This is another example of due process violations by Judge Steven
Nordquist.
6. That during a number of court appointed days for the Plaintiff, Rhonda’s case,
who has been Pro Se, Judge Steven Nordquist would come into court in a
condition that did not enable him to function properly on the bench; that he
cancelled court a number of times and was late as much as two hours for
Plaintiff’s case on one occasion.
30
7. That on August 27, 2004, after a court order was entered by Steven Nordquist, at
the behest of Kathryn Bischoff, making Kathryn Bischoff, Child Rep., responsible
for the transfer of Cheyenne’s drugs, she locked the drugs in her office and left for
a three day holiday with no notice to the Plaintiff, Rhonda. (GROUP EXHIBIT
#37). The order alluded to was necessitated by Giles’ manipulation of the drugs
for Cheyenne, including allegedly stealing same from the Walgreen's Pharmacy,
see Police report #03-054747 (GROUP EXHIBIT #37). After Kathryn Bischoff
learned that the absence of drugs for Cheyenne led to a series of events that were
detrimental to Cheyenne’s physical well-being, that led to a DCFS investigation
and police investigation. Kathryn Bischoff assisted Giles in court to obtain an
OOP (GROUP EXHIBIT #35). On information and belief, Plaintiff, Rhonda
believes that Kathryn Bischoff helped word the petition and the OOP with false
allegations and committed a fraud upon the court as well as giving perjurious
testimony. Due to the fact that Kathryn Bischoff was then the Child
Representative and a former Department of Children and Family Services
Supervisor, she was able to fend off the investigation and steer same away for
Giles Denham and herself. Also during this time, Cheyenne sustained two (2)
head injuries as the result of the complications from the inappropriate medications
and required hospitalization.
8. As a result of the OOP (that had expired), the court ordered DCFS supervision,
and by the directive of the father, Giles, the Rockford Public School attended by
Cheyenne has refused to permit Plaintiff, Rhonda, from being active in and
participate in all levels of Cheyenne’s education, including some Federal I.E.P.s
and functions in the classroom and the auditorium. As recently as February 14,
2007, and March 23, 2007, the school principal refused to allow Plaintiff, Rhonda
Griffith-Kraut, to have any contact with the minor, including an attempt by
Plaintiff, Rhonda, to give the minor, Cheyenne, a Valentine’s day card at school
and a request to observe Cheyenne in her classroom. (GROUP EXHIBIT #28).
9. Petition Regarding Visitation Abuse filed on 6-29-01, by Plaintiff, Rhonda,

alleging visitation abuses by Giles Denham are still pending for almost seven (7)
years have never been heard by presiding Judge Steven Nordquist. (GROUP
EXHIBIT #38).
10. On Oct. 18, 1999, Giles Denham’s counsel Cheri Greenlee filed a Petition to
Establish the Parent-Child Relationship. (GROUP EXHIBIT #39). Plaintiff,
Rhonda received a Summons to appear on Dec. 2, 1999 issued by Cheri Greenlee,
counsel for Giles Denham. (GROUP EXHIBIT #39). Plaintiff, Rhonda filed an
Answer to Petition to Establish the Parent-Child Relationship on or around Jan.
27, 2000 (GROUP EXHIBIT #39). A copy of Cheyenne Renee Griffith’s original
birth certificate will show that the father’s name is marked “legally omitted”.
(GROUP EXHIBIT #39). Judge Steven Nordquist Order Establishing the Parent-
Child Relationship signed on Jan. 1, 2004 states therein: “the biological father of
said child is Giles R. Denham, Petitioner, who currently reside ….. Racine,
Wisconsin.” Judge Steven Nordquist further ordered: “It is therefore ordered
31
that the parent-child relationship between Giles R. Denham and Cheyenne
Renee Griffith be established and that a new birth certificate be issued by the
State of Illinois so identifying Petitioner as her natural father.” The Plaintiff,
Rhonda never signed a Voluntary Acknowledgment of Paternity form. Judge
Steven Nordquist did not order any DNA testing to confirm that Giles R. Denham
was the natural father to Cheyenne Renee Griffith prior to ordering the change in
the minor, Cheyenne’s birth certificate. (GROUP EXHIBIT #39).
11. Kathryn Bischoff, Child Representative for minor, Cheyenne Griffith, as

evidenced in her billing, did not meet with the minor, Cheyenne, for extended
time periods as long as 17 months and again for another time period as long as 19
months.
12. Plaintiff, Rhonda, Pro Se filed a Motion for Vacation of Supervised visitation and
Emergency Petition for Change of Custody on May 7, 2007 and Notice said
Motion for hearing on May 24, 2007 at 9:30 a.m. In said motion, Plaintiff,
Rhonda has asked for Giles Denham to be ordered to submit to DNA testing to
prove parentage. In addition, the issue of custody, which was transferred to Giles
Denham without a hearing and without DNA testing, utilizing an Order of
Protection as a cloak; and the ongoing supervised visitation ordered by Judge
Nordquist, without any grounds. Judge Steven Nordquist, with the assistance of
Kathryn Bischoff, Child Representative, had violated the Plaintiff, Rhonda’s due
process rights and the 14th Amendment of the United States Constitution with said
rulings in the 17th Circuit Court. (GROUP EXHIBIT #39).
13. Defendant, Judge Steven Nordquist threatened the Plaintiff, Rhonda, to have a
bench warrant issued for her arrest in order to restrain her from proceeding.
(GROUP EXHIBIT #38). All the allegations contained in this count relating to
Plaintiff, Rhonda, constitute gross abuses of Rhonda’s Constitutional Rights and
her child’s constitutional rights of Due Process and is a clear violation of the 14th
Amendment.
CLASS ALLEGATIONS
1. Deborah Orlando Cooney brings this action pursuant to Federal Rule Civil
Procedure 23(a)(b) on behalf of herself and a class (the “Class”) consisting of
herself and others who have suffered the same result at the hands of at least two
defendants, Judge Steven Nordquist and Kathryn Bischoff. At least two others
have had serious Constitutional violations of theirs and their children at the hands
of the said Defendants, namely, Julia Bornhuetter-Colloton and Rhonda Griffith-
Kraut.
2. There is an ongoing course of conduct by Judge Steven Nordquist with regard to

Julia Bornhuetter-Colloton and Rhonda Griffith-Kraut which renders their ability
to obtain a fair trial a nullity. The individual Plaintiffs believes there are more
32
mothers who have lost custody of their children and suffered other abuses at the
hands of one or more of the defendants and who will come forward once this
cause of action is filed.
1. Common questions of law and fact exist as to all members of the Class and
predominate over questions affecting individual members. Common questions for
the Class include, but are not limited to:
a. Did the defendants either in consort with all mentioned or more than one
involve themselves in a conspiracy to violate the Plaintiff’s and the Class’
Constitutional Rights?
b. Did the defendants, either intentionally or willfully violate the
Constitutional rights as described herein.
c. Does the traditional Judicial Immunity apply to relieve defendant
Nordquist of his culpability.
d. Did the defendants individually or in consort, hide and suppress evidence
that was favorable to the Class?
e. Does the conduct of the defendants either individually or in consort rise to
the level of intentional infliction of emotional distress?
2. Deborah Orlando Cooney will fairly and adequately protect the interests of the
Class; her claims are typical of the claims of the members of the class; she has
retained counsel competent and experienced in this field who has been involved in
representing Deborah Orlando Cooney since on or about July, 2005 and who has
had ongoing involvement with the other two named members of the class.
3. A class action is superior to other available methods and causes of action for
fairly and efficiently adjudicating this controversy because, among other things,
(a) many members of the proposed class have insufficient funds to retain
individual counsel and they cannot carry the expense of individual litigation and
(b) joinder of all members of the class is impractical.
COUNT I
(Violations of Constitutional Rights)
The Plaintiffs claim a multitude of violations of their Illinois Statutory rights as well as
the violations of the Federal Constitution. The description of the activities of the
defendants clearly abridged the rights of the plaintiffs and violated the following:
a. U.S. Code Title 18, part I, Chapter 13, 241-conspiracy against rights
b. U.S. Code Title 42, Chapter 21, Subchapter I, 1983 Civil Action for Deprivation
of Rights
33
c. Violations of the 14th Amendment for the Care, Custody and Control of children
d. Equal Protection of the Laws and the Federal Case Law of the U.S. Supreme Court
of the United States, Jarrett v Jarrett, No.79-1735
e. Violations of their oaths to uphold the Constitution of the United States of

America and the Constitution of the State of Illinois
f. Article VI Clause 2- This Constitution, and the Laws of the United States which
shall be made in Pursuance thereof; and all Treaties made, or which shall be made,
under the Authority of the United States, shall be the supreme Law of the Land;
and the Judges in every State shall be bound thereby, any Thing in the Constitution
or Laws of any State to the Contrary notwithstanding.
g. Illinois Law General Provisions, 5 ILCS 160/3 (a) all records created or received
by or under the authority of or coming into the custody control or possession of
public officials of this State in the course of their public duties are the property of
the State. These records may not be mutilated, destroyed, transferred, removed, or
otherwise damaged or disposed of, in whole or in part, except as provided by law.
h. U.S. Code Title 42, Chapter 21, 1986-Action for neglect to prevent- “…every
person who, having knowledge that any of the wrongs conspired to be done…are
about to be committed, and having power to prevent or aid in preventing the
commission of the same neglects or refuses to do so, if such wrongful act
committed, shall be liable to the party injured…for all damages caused by such
wrongful act.”
CONSPIRATORIAL ACTS OF DEFENDANTS
The Plaintiff, Deborah Orlando Cooney, alleges as conspiratorial acts against Dr. Lyle
Rossiter, Jr., Kathryn Bischoff, Dan Cain, and Judge Steven Nordquist, the following:
1. Kathryn Bischoff, attorney at law, was appointed to act as child representative of

the two minor children of the Orlando family, Christopher and Jonathan. This
appointment was made on Oct. 17, 2002 by Judge Steven Nordquist (EXHIBIT
#6). On 7-17-03 Plaintiff, Deborah Cooney’s counsel Alex Abate Motioned to
update a psychological evaluation of the parties and children due to post judgment
custody litigation (GROUP EXHIBIT #32).
2. Laurie Orlando, wife of Lorenzo, selected Dr. Lyle Rossiter, Jr., allegedly from
the internet and called him on August 31, 2004, and again on September 3, 2004,
three (3) weeks before a court order orchestrated by Kathryn Bischoff was entered
appointing Dr. Rossiter on Sept. 23, 2004. (EXHIBIT #1). In the Order dated
Sept. 23, 2004 Kathryn Bischoff was the only attorney that was allowed to
communicate with Dr. Rossiter. In the notes from Dr. Rossiter’s files it was
34
ascertained that on August 31, 2004 (GROUP EXHIBIT #32) on last line, he
wrote, among other things, that Deborah’s parents are rich. On September 3,
2004 (GROUP EXHIBIT #32), on lines 7 and 8, Rossiter’s notes revealed a plan
“to have Bischoff call him” and then have him appointed as a custodial evaluator
pursuant to 750 ILCS 5/605.
3. From that point forward a series of events occurred that culminated in a court
order entered on June 15, 2005, by Defendant, Judge Steven Nordquist that not
only transferred custody of the minor children (GROUP EXHIBIT #3); it also
provided for no contact and an emergency order of protection against Deborah
Cooney with a finding that she was suicidal and armed. (GROUP EXHIBIT #4).
Dr. Rossiter’s report did not recommend “No Contact”. The Order of Protection
form was filled out by Dan Cain, counsel for Lorenzo Orlando. The order was
entered in violation of 750ILCS 5/605 and the Domestic Violence Act.
4. On June 14th, the Defendants Judge Steven Nordquist, Kathryn Bischoff, Dan
Cain, along with Deborah’s counsel, Alex Abate, had a chamber conference
which, as a result thereof, Judge Steven Nordquist entered a “gag order”
preventing the attorneys from revealing the discussion about the results of
Defendant, Dr. Rossiter’s report (EXHIBIT #11). Either Kathryn Bischoff, Judge
Steven Nordquist or both of them had previously revealed the report to Lorenzo’s
attorney, Dan Cain, and no one revealed that fact to Deborah’s counsel. Kathryn
Bischoff testified that Dan Cain took control of the meeting in chambers.
5. On the 15th of June, 2005, without any notice to Deborah, and in violation of her
Due Process rights, Judge Steven Nordquist entered the said orders (GROUP
EXHIBIT #3, and #4). The violation of the “gag order” (EXHIBIT #11) because
the petitions filed by Lorenzo were signed and notarized the 13th of June, 2005,
one (1) day before the chamber conference and the issuance of the “gag order”.
(GROUP EXHIBIT #3).
6. As a result of the orders of June 15, 2005 for an Order of Protection and Change
in Custody, and in violation of the minor, Christopher Orlando’s rights, he was
handcuffed by employees of the Rockford Detective Agency, at the instructions of
Dan Cain, and taken to Swedish American Hospital for psychiatric intake without
a court order for Judicial Commitment or Involuntary psychiatric hospitalization.
(EXHIBIT #26).
7. All that transpired on June 15th, 2005, took place without a hearing; without the
right that should have been accorded Deborah to confront her accusers; her right
pursuant to Section 605 to cross-examine, and numerous other due process
violations. (EXHIBIT #5).
8. That thereafter, numerous other conspiratorial acts and violations of Deborah’s

rights and the children’s rights occurred: The emergency order of protection,
which, by statute, has a maximum life of 21 days, was continued by Judge Steven
35
Nordquist on numerous occasions, without the matter being in court. It was
extended once by Judge Steven Nordquist by U.S. mail with no notice to Deborah
Cooney, which violated section 750 ILCS 60/220 (ii)(e) of the statute which
requires matters to be heard in open court (GROUP EXHIBIT #23); it (OOP) was
continued on one occasion by Judge Nordquist on Sept. 22, 2005 (GROUP
EXHIBIT #23), after the time expired for the ability to extend the order; it was
continued twice (2) with notes from Judge Steven Nordquist stating that Deborah
and her counsel appeared to object to an extension of the emergency order of
protection in spite of the fact that on one of the occasions neither Deborah nor her
attorney, Stanley Kaplan, were present as the attorney was in Arizona and on the
other occasion the attorney was attending the funeral of his cousin. These
notations in the Court Docket Sheet, which is the official record, were then altered
after pleadings filed by Deborah. (GROUP EXHIBIT #30). Letters from Chief
Judge Zenoff stating that she could not explain how Judge Steven Nordquist could
write blue sheets when there was no court, or when people were not present.
(GROUP EXHIBIT #30). The emergency order of protection continued in
existence from June 15, 2005, until December 19, 2006 when Judge Brian Shore
was to hear the case, he had an agreed order entered dismissing the petition for
order of protection and vacating the emergency order of protection. (GROUP
EXHIBIT #23). On several occasions, Plaintiff’s attorney filed Petitions to vacate
and dismiss the Order of Protection due to “no grounds” which were denied.
(GROUP EXHIBIT #27). That emergency order of protection existed for more
than 18 months, causing Deborah and the children significant emotional and
physical distress and extensive monies being expended, and violated their
constitutional rights.
9. That during the pendency of the post judgment custody matter, the Defendant,
Kathryn Bischoff, who was to protect the best interests of the minors, in her own
testimony admitted that she never spoke with the Orlando minors for about one
(1) year since June 15, 2005; orchestrated the beginning of a “witch hunt” against
Deborah claiming Munchausen’s by Proxy and planting the seed in Defendant Dr.
Rossiter’s mind about the same, see letter dated Oct. 19, 2004 in which Kathryn
Bischoff wrote: “My concern from reading the medical reports is this may be
a situation of Munchausen syndrome (on the part of the Mother)”. (GROUP
EXHIBIT #32). Kathryn Bischoff gave testimony on two (2) separate occasions
that she did not have any medical records nor did she recall any medical records
for the minor. Kathryn Bischoff at the Administrative Hearing testified that she
had one (1) training session on Munchausen in 1986 which lasted about 20
minutes. She also testified that she had one (1) case of Munchausen, while she
was a Supervisor at Department of Children and Family Services. She stated that
she had no other additional training or ICLE classes since.
On Nov. 1, 2004, Dr. Rossiter wrote to Kathryn Bischoff wherein he stated:

“Your brief summary is helpful, as is the attached court order”. (GROUP
EXHIBIT #32). Kathryn Bischoff was subpoenaed for deposition to take place on
April 30, 2007 and to bring records. Kathryn Bischoff did not comply with the
36
subpoena and chose to bring only certain communications between the parties.
During Kathryn Bischoff’s testimony she was asked to provide her copy of the
“brief summary” mentioned in Dr. Rossiter’s letter of Nov. 1, 2004, which she
sent to him on Oct. 19, 2004. Kathryn Bischoff could not provide a copy, and
stated that the letter was her brief summary, even though the letter of Oct. 19,
2004 lists “Enclosures”. (GROUP EXHIBIT #23).
On May 5, 2005, Kathryn Bischoff wrote a letter to Dr. Rossiter and therein
stated: “Attorney Cain has asked that I express to you his client’s desire that
your report be completed as quickly and expeditiously as possible believing
that whatever the report contains Ms. Cooney will contest and wish to
conduct depositions.” See letter dated May 5, 2005. (GROUP EXHIBIT #32).
Query: How could such a statement be made on May 5, 2005 when Dr. Rossiter’s
report was not completed until June 10, 2005 which is 35 days after this comment
made by Dan Cain to Kathryn Bischoff?
On May 9, 2005, Dr. Rossiter wrote a letter to Kathryn Bischoff and attached a
list of Christopher’s medical contact in 2004 for which he did not have records.
See letter dated May 9, 2005. (GROUP EXHIBIT #23). On May 10, 2005,
Kathryn Bischoff then wrote to Plaintiff, Deborah, therein Bischoff stated: “Dr.
Rossiter is requesting to receive copies of these to be included in his
evaluation and I also need to review the records for my investigation.
Therefore, please obtain copies of each of these records and provide them to
me as soon as possible.” The attached list consisted of about 35 medical contacts
including four (4) emergency room visits. (GROUP EXHIBIT #32). Dr. Rossiter
never asked Deborah, in a meeting on May 9, 2005 for medical records of 2004,
notwithstanding the importance given to the records by both Dr. Rossiter and
Kathryn Bischoff. Dr. Rossiter failed to discuss or advise Deborah of the need for
medical records.
On June 5, 2005, Kathryn Bischoff in testimony and from her billing admitted
that she received one of the drafts from Dr. Rossiter, but only 23 pages of it. The
final draft was not telefaxed to Kathryn Bischoff from Dr. Rossiter until June 10,
2005 which had 2 pages in the midst of the same draft with a telefaxed date of
June 14, 2005. On April 30, 2007, Kathryn Bischoff testified that she destroyed
the Motion for Hospitalization that she drafted on June 14, 2005 while still billing
the Plaintiff, Deborah. Kathryn Bischoff further testified that the Motion for
Hospitalization was never filed.
The 605 Evaluation by Dr. Rossiter was completed on June 10, 2005, but there
are still numerous correspondences between Kathryn Bischoff and Dr. Rossiter
thereafter. On Nov. 2, 2005 letter from Kathryn Bischoff to Plaintiff, Deborah’s
attorney Stanley Kaplan, wherein she wrote: “I have informed Dr. Rossiter that
his deposition may not go forward on Nov. 28, 2005 at 2:00 p.m. Even if all of
the attorneys and Dr. Rossiter are available on that date and time, there is
still the issue of Dr. Rossiter’s fees.” See letter dated Nov. 2, 2005 (GROUP
37
EXHIBIT #32). On Nov. 8, 2005 Stanley Kaplan, counsel for Plaintiff, Deborah
wrote a letter to Kathryn Bischoff wherein he stated: “Why Dr. Rossiter is
having an issue of his fees dealt with by you is something that I don’t
understand since you represent the children and not Dr. Rossiter.” See letter
dated Nov. 8, 2005. (GROUP EXHIBIT #32).
On Nov. 15, 2005, Dr. Rossiter wrote a letter to Kathryn Bischoff and stated
therein: “Thank you for the faxed copy of your letter dated yesterday,
11/14/2005., to Mr. Kaplan, and the copy of the 9/23/2004 court order. It
happens that I also received a second letter from Mr. Kaplan yesterday. A
copy is attached to this fax. I assume that I should not reply just yet. Please
Advise.” See letter dated Nov. 15, 2005. (GROUP EXHIBIT #32). Query: Why
would Dr. Rossiter ask Kathryn Bischoff, Child Representative for the Orlando
minors, to advise him?
On Dec. 3, 2005 Dr. Rossiter wrote a letter to Kathryn Bischoff wherein she
stated: “I am quite certain Deborah’s parents can pay both of our fees.
Lorenzo’s resources are more limited.” See letter dated Dec. 3, 2005. (GROUP
EXHIBIT #32).
Kathryn Bischoff had the medical diagnoses of Christopher Orlando and had the
list of hospitals and doctors and knew, or should have known, that Munchausen
by Proxy could not exist. See letter dated Jan. 7, 2005 (GROUP EXHIBIT #32).
Yet, Kathryn Bischoff and Dr. Lyle Rossiter, with the aid of Judge Steven
Nordquist, Dan Cain, and Brian Klaung continued the ongoing violations of
Plaintiff, Deborah’s rights, and the rights of the Orlando minors’, Christopher and
Jonathan.
On June 30, 2005 Kathryn Bischoff testified that she received a certified letter
from the Plaintiff, Deborah, with the enclosures of the Letter dated June 22, 2005
from Children’s Memorial Hospital. The Children’s Memorial Hospital letter
indicated all of the minor, Christopher Orlando’s, medical diagnoses for which he
has been receiving treatment for at Children’s Memorial Hospital. Christopher’s
diagnoses are: Allergic rhinitis, Moderate persistent asthma, Food allergies (Milk,
peanut, and tree nut allergies), drug allergies and Porphyria. In addition to the
letter were enclosures describing the asthma action plan; signs of an allergic
reaction; how to use an Epipen; how to read labels for milk free diet; how to read
labels for a tree nut free diet; how to read labels for a peanut free diet; and a list of
medications that Christopher Orlando is allergic too. All of which Kathryn
Bischoff, the Child Representative, ignored. (GROUP EXHIBIT #32)
ISSUE OF LAW AS IT RELATES TO JUDICIAL IMMUNITY
1. It is clear from reading the cases relating to the issue of judicial immunity that
members of the judiciary enjoy an immunity from suit that some have designated
38
“absolute immunity.” That term is a term of art and is not to be applied to cloak
the members of the judiciary when they are egregious in their conduct and violate
the Constitutional Rights of citizens of the United States of America.
2. The United States Constitution provides protects the people, their property and
that all people will be treated equally. The First Amendment is the basis of our
democratic process. The First Amendment forbids Congress to pass laws
restricting our freedom of speech, of the press, of peaceful assembly and/or the
right of petition. The Supreme Court has ruled that the Fourteenth amendment
makes the guarantees of the First Amendment apply to the state government. Due
Process is a requirement of the United States Constitution to guarantee justice and
liberty to its citizens. Due process provides that all individuals are protected and
ensured that no one is deprived of life, liberty or property, arbitrarily and without
an opportunity to affect the judgment or result. Due process includes court
procedures that protect individuals accused of wrongdoings and the Sixth
Amendment provides a right to know the charges and to provide evidence to
prove their innocence or the support the charges. Violations, by Judge Steven
Nordquist, and ALJ Daniel Baechle, of the United States Constitution, deprive
that person from acting as a judge under the law. He is acting as an individual and
not in the capacity of a judge and, is therefore, stripped of the immunity and is
subject to suit.
3. In Cooper v Aaron, 358 U.lS.1, 78 S.Ct. 1401 (1958), the court stated that:
No….judicial officer can war against the constitution without violating his
undertaking to support it. While a judge may issue orders to control his court, he
has no lawful authority to issue any order which violates the Supreme Law of the
Land. The First Amendment ensures that all have the mandatory right of
adequate, complete, effective, fair, full, meaningful and timely access to the court.
The Fifth and Fourteenth Amendments guarantee due process and equal
protection to all. “No state shall deprive any person of life, liberty or property
without due process of law, nor deny to any person within its jurisdiction the
equal protection of the laws.” The Constitution of the United States, 14th
amendment states, “Choice about marriage, family life, upbringing of children are
among associated rights ranked as of basic importance to our society, rights
sheltered by the Fourteenth Amendment against the State’s unwarranted
usurpation, disregard or disrespect. U.S.C.A. Constitutional Amendment 14.
4. Judge Steven Nordquist was petitioned to recuse himself due to clear bias,
violations of state statutes, federal statutes, the Constitution of the United States,
and he refused. He went so far as when he ultimately was taken off the case, put
himself back on, again to violate Deborah’s rights. Judge Steven Nordquist
should have recused himself as far back as June, 2005. According, to United
States v Sciuto, 521 F.2d 842 (7th Cir. 1996) “The right to a tribunal free from bias
and prejudice is …based on the Due Process Class. The issue of recusal and the
motion for substitution of judges is “directed against the appearance of partiality
whether or not the judge is actually biased.” United States v Balistrieri, 779 F.
39
2d, 1191 (7th Cir. 1985). Illinois Supreme Court Rule 63 C (1) states that “a judge
shall disqualify himself or herself in a proceeding in which the Judge’s
impartiality might reasonable be questioned…”
5. In Cooper v Aaron, 358 U.S. 1, 78 S.Ct. 1401 (1958), and Scheuer v Rhodes, 416
U.S. 232, 94 S.Ct. 1683, 1687 (1974) the courts have held that when a judge fails
to support the Constitution, the judge is not acting in any judicial capacity, but is
acting only in his/her personal capacity. His/her orders are void, of no legal force
or effect, and he/she has been deprived of any protection of the government.
He/she is amenable to personal suit, as the judge does not have judicial immunity
for acts in his/her personal capacity. Whenever a judge has violated a person’s
Constitutional Rights, the judge has lost jurisdiction in that action, for he no
longer is acting as a judge, but is acting only in his person.”
Wherefore, Plaintiffs pray as follows:
A. That Judgment be issued against Defendants individually and jointly in the

amount of $300,000,000.00 ($300 million) or such great sums that this Court
deems appropriate for the substantial injustices and wrongs perpetrated against
the Plaintiffs by Defendants named herein.
B. For such other further relief as to this Court shall seem just and equitable.
_____________________________
_
Deborah Orlando Cooney, Plaintiff
______________________________
Rhonda Griffith-Kraut, Plaintiff
______________________________
Julia Bornhuetter-Colloton, Plaintiff
Prepared by:
Stanley F. Kaplan
Attorney for Plaintiffs
500 Skokie Blvd., Suite 350
Northbrook, Illinois 60062
40
847-849-4800
Atty Code:
41
STATE OF ILLINOIS )
) SS
COUNTY OF COOK )
I, , being first duly sworn on oath, state that I have read the above
and foregoing pleading by me first subscribed and believe the contents to be true in both
substance and in fact with the exception of those allegations stated to be upon
information and belief and with respect to those allegations I also believe them to be true
pursuant to Illinois Code of Civil Procedures, Section 1-109.
_____________________________
_
Deborah Orlando Cooney, Plaintiff
______________________________
Rhonda Griffith-Kraut, Plaintiff
______________________________
Julia Bornhuetter-Colloton, Plaintiff
Subscribed and Sworn to before

Me this ____ day of ________
2007.
__________________________
Notary Public
CERTIFICATION OF COUNSEL
STANLEY F. KAPLAN, attorney for , pursuant to Rule 137 of the

Illinois Supreme Court, states that he has read the above and foregoing pleading, that to
the best of his knowledge, information and belief, formed after reasonable inquiry, said
pleading is well grounded in fact and is warranted in existing law, and that said pleading
is not interposed for an improper purpose, such as to harass or to cause unnecessary delay
or needless increase in the cost of litigation.
42
______________________________
STANLEY F. KAPLAN
43

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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

DEBORAH ORLANDO COONEY, RHONDA GRIFFITH- )

CLASS ACTION COMPLAINT

Plaintiffs, Deborah Orlando Cooney hereinafter known as Deborah, Rhonda Griffith-

NATURE OF THE CASE

1. Plaintiff Deborah is a resident of the State of Illinois and residing in Cook

On Oct. 7, 2005 conducted a critique of Dr. Rossiter’s 605 custodial

E. Besides the Department of Children and Family Services violating the

G. DCFS’ Administrative Law Judge, Daniel Baechle, denied the Plaintiff,

Dan Cain presented alleged documents to Rockford Police Detective, Dan

In contradiction to John Budzynski’s statements, the Court Order of Dec.

Note from Swedish American Health System Emergency Department

In Plaintiff Rhonda’s case, Kathryn Bischoff, the court appointed Child

In Plaintiff Deborah’s Case: A Rockford Police officer badge #537 was

L. Department of Children and Family Services - In Plaintiff Julia’s case: A

In Plaintiff Rhonda’s case: On Oct. 19, 2004 Giles Denham’s counsel,

On Feb. 9, 2005 DCFS’ Director, Bryan Samuels, granted Rhonda’s appeal

On March 1, 2005 Illinois Department of Children and Family Services

Another issue involving DCFS, on 1-13-05 Plaintiff, Rhonda telefaxed from

On Feb. 10, 2005, Plaintiff Rhonda telefaxed a letter to Mary Morrison,

On March 16, 2005 DCFS, Mary Morrison telefaxed a letter to Rhonda

DCFS Service plan of 4-1-2005 and revised on 9-13-2005 for Rhonda.

M. Brent Johnson, Supervisor of Department of Children and Family Services

On Oct. 13, 2000, Judge Steven Nordquist ordered: “that on an interim

Report by David Jacobsen dated 11-21-2000 with recommendation #1 stated

Dr. David Jacobsen notified on 12/20/2000 by Michael Raridon, GAL, for

Illinois Department of Professional Regulations (IDPR) on April 6, 2004

O. Rockford Public Schools - Kristin Schroeder, Cheyenne's special education

Schroeder allegedly made a false report to the D.C.F.S. hotline on 8-27-04

On June 6, 2006, Rhonda wrote a letter to Lynell Kenny, Principal, at Spring

On Nov. 1, 2006, Rhonda wrote a letter to Mrs. Greenburg at Spring Creek

FACTS RELATING TO THE NAMED PLAINTIFF, DEBORAH

1. The Plaintiff, Deborah, named herein was involved in a post judgment

2. After numerous court appearances, Judge Steven Nordquist, after having

5. As a result of Judge Steven Nordquist’s orders of June 15, 2005, Plaintiff,

6. A factual list of the continuing violations of Judge Steven Nordquist, including

7. Plaintiff, Deborah obtained an Emergency Order of Protection on behalf of minor,

On Oct. 3, 2005, Todd Schroeder, Trial Court Administrator in Winnebago

On Feb. 3, 2006, Todd Schroeder, Trial Court Administrator wrote a letter to

FACTS RELATING TO THE NAMED PLAINTIFF, JULIA

3. On Sept. 26, 2000, without a hearing, Judge Steven Nordquist entered a

6. That David Jacobsen had misrepresented himself, as a psychologist, when he was

8. Plaintiff, Julia’s counsel, Chester Chostner, Amended Motion to Vacate or

13. On October 23, 1997, notwithstanding documented domestic violence (GROUP

FACTS RELATING TO NAMED PLAINTIFF, RHONDA

1. While the Plaintiff, Rhonda was at Centegra Hospital in Woodstock, Illinois, on

All of the extensions of Ex parte Order of Protection (GROUP EXHIBIT #35)

On 9-16-04, Judge Nordquist extended OOP to 9-30-04 equaling (15 days)

On 6-22-05, Judge Steven Nordquist proceeded to a plenary hearing, when in fact

9. Petition Regarding Visitation Abuse filed on 6-29-01, by Plaintiff, Rhonda,

11. Kathryn Bischoff, Child Representative for minor, Cheyenne Griffith, as

2. There is an ongoing course of conduct by Judge Steven Nordquist with regard to

(Violations of Constitutional Rights)

e. Violations of their oaths to uphold the Constitution of the United States of

CONSPIRATORIAL ACTS OF DEFENDANTS

1. Kathryn Bischoff, attorney at law, was appointed to act as child representative of

8. That thereafter, numerous other conspiratorial acts and violations of Deborah’s

On Nov. 1, 2004, Dr. Rossiter wrote to Kathryn Bischoff wherein he stated:

ISSUE OF LAW AS IT RELATES TO JUDICIAL IMMUNITY

Wherefore, Plaintiffs pray as follows:

A. That Judgment be issued against Defendants individually and jointly in the

Subscribed and Sworn to before