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1 IN THE TWENTY-FIRST JUDICIAL CIRCUIT COURT SAINT LOUIS COUNTY, MISSOURI EVITA TOLU ) ) Plaintiff ) ) v. ) Cause No. 20SL-CC4680 ) JAMES D. REID, PH.D., et al ) Division No. 12 ) Defendants. )

PLAINTIFF’S

FIRST AMENDED PETITION AND DEMAND FOR TRIAL BY JURY

COMES NOW, Plaintiff, Evita Tolu (

“Plaintiff”) and for

her Petition against Defendants James D. Reid, Ph.D., James D. Reid, Ph.D., LLC (collectively

“Reid”)

, Elaine Pudlowski

(“Pudlowski”), Jennifer

Webbe Van Luven

(“Van Luven”)

and Fitzgibbons Psychological Associates, also known as, West County Psychological Associates (

“WCPA” and/or “Van Luven”)

, who provided services to Plaintiff, states as follows:

PARTIES, JURISDICTION AND VENUE

1.

Plaintiff is an individual who resides in Saint Louis County, Missouri. 2.

Defendant Pudlowski is an attorney licensed to practice law in the State of Missouri with her principle place of business in Clayton, Saint Louis County, Missouri. 3.

Pudlowski was a Court appointed Guardian ad Litem (GAL) on August 30, 2017, in

Plaintiff’s custody modification case,

Tolu v. Stientjes, Case No. 16SL-DR04088-01, Saint Louis County Circuit Court. A copy of the Order Appointing Defendant Pudlowski is attached as

Exhibit 1

. 4.

Defendant Reid is a Missouri licensed psychologist, with his principal place of business in Clayton, Saint Louis County, Missouri.

E l e c t r oni c al l y F i l e d - S t L o ui s C o un t y -D e c em b er 0 4 ,2 0 2 0 - 0 4 : 2 4 P M

2 5.

Defendant James D. Reid Ph.D., LLC is a Missouri limited liability company with the principal place of business in Clayton, Saint Louis County, Missouri. At all relevant times hereto, Reid acted within the scope and course of his employment, servancy and/or agency for James D. Reid, Ph.D., LLC. 6.

On October 26, 2017, the Court appointed Reid as an expert in Plaintiff’s custody

modification case, Tolu v. Stientjes, Case No. 16SL-DR04088-01, Saint Louis County Circuit Court

, to “evaluate the psychological status of Pe

titioner and Respondent, and their two minor children, and to assess any allegations or issues regarding their current mental health and the parenting ability of each parent specific to this case bearing on the best interests of their two minor children. T

he Evaluator shall offer opinions and recommendations regarding this case” and to “exercise his independent objective judgment in conducting the evaluation.” A copy of the Court

Order Appointing Reid is attached as

Exhibit 2

. 7.

Defendant Van Luven is a Mi

ssouri Licensed Clinical Social Worker (“LCSW”),

with her principal place of business at Fitzgibbons Psychological Associates a/k/a West County Psychological Associates located in Creve Coeur, Saint Louis County, Missouri. 8.

Defendant Fitzgibbons Psychological Associates is a professional entity conducting business under the fictitious name of West County Psychological Associates (sometimes referred

to as “Fitzgibbons” and

/or

“WCPA”), with its principal place of business in Creve Coeur, Saint

Louis County, Missouri. At all relevant times hereto, Van Luven acted within the scope and

course of her employment, servancy and/or agency for WCPA and at WCPA’s location in Creve

Coeur, Saint Louis County, Missouri. 9.

On September 17, 2018, the Court appointed Defendant Van Luven, who was employed at WCPA at the time of the appointment, to act as a custody support professional and a


3 therapist for Plaintiff and her children. Van Luven and subsequently WCPA accepted the Court Appointment as litigation support professionals to conduct family and child reunification therapy

to Plaintiff and her children in Plaintiff’s custody modification case,

Tolu v. Stientjes, Case No. 16SL-DR04088-01, Saint Louis County Circuit Court. 10.

On her firm’s website

,

1

Pudlowski holds herself to the public and the Saint Louis County Courts as an attorney with an extensive practice in the field of domestic relations where she represents both men and women in matters pertaining to divorce, paternity, child custody, child support and spousal support. According to her website,

Pudlowski’s expertise extends to

the juvenile court where she handles adoptions as well as the probate court where she assists families with legal guardianships and estates. Pudlowski states that she is a certified Guardian ad Litem, a mediator, and a parent coordinator. Pudlowski is a frequent author and lecturer in the area of family law. 11.

Pudlowski holds herself out as a court appointed Guardian ad Litem representing minor children in every courtroom in both the Saint Louis City and the Saint Louis County Circuit Courts, with twenty years of experience in representing children. Defendant Pudlowski also states that she is a personal injury lawyer in civil lawsuits and handles a variety of civil and traffic matters. According to Pudlowski she has tried hundreds of cases throughout the Saint Louis Metropolitan area and surrounding counties. 12.

On his website,

2

Reid holds himself out to the public and to Saint Louis County Courts as a career court expert in criminal, civil, and family law cases, a Forensic Psychology Professor, who conducts psychological assessments and provides court testimony for a living. Reid also holds himself out as a mediator who helps people resolve conflicts in an effective

1

https://www.frankelrubin.com/about-us/our-attorneys/elaine-a-pudlowski/

2

http://james-d-reid-phd.com/
