HomeMy WebLinkAbout03-3726
II
LAWRENCE L. VERDEKAL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.2003- 3 72("
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of divorce or annulment may be
enteri:ld against you by the court. A judgment may also be entered against you for any
othen claim or relief requested in these papers by the Plaintiff. You may lose money or
propejrty or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marri<ilge, you may request marriage counseling. A list of marriage counselors is
availaible in the Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU
DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
II
LAWRENCE L. VERDEKAL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2003- 37 J.&
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301 (C)
AND 3301 (D) OF THE DIVORCE CODE
1. Plaintiff is Lawrence L. Verdekal, Jr., an adult individual whose domicile is
1576 Newville Road, Carlisle, Cumberland County, Pennsylvania. The Plaintiff is
currently in the United States Army on active duty.
2. Defendant is Maria E. Verdekal, an adult individual who currently resides
at 311 Kerrsville Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on February 1, 2002 in
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that he
may have the right to request that the court require the parties to participate in
counseling.
II
8. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in
favor of the Plaintiff and against the Defendant.
COUNT II-ADUL TRY
9. The allegations in paragraphs one through eight, inclusive are made a
part hereof and incorporated herein by reference.
10. The Plaintiff alleges that in violation of her marriage vows, the Defendant
has over a period, in Cumberland County, and other places offered such indignities to
the person of the Plaintiff as to render his condition intolerable and life burdensome.
11. This action in divorce is not conclusive.
12. The Defendant has engaged in adulterous conduct during the marriage.
WHEREFORE, Plaintiff prays your Honorable Court to enter a decree in divorce.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
~~
Michael A. Scherer
1.0.# 61974
17 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
mas.dir~domestic/verdekal/complaint.pld
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.s. ~ 4904, relating to unsworn falsification to authorities.
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Lawrence L. Verdekal) .Jr.
Date: 1/10/0;
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LAWRENCE L. VERDEKAL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003-3726 CIVIL TERM
vs.
IN DIVORCE
MARIA E. VERDEKAL,
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Dear Sir:
Please enter my appearance on behalf of Maria E. Verdekal,
Defendant.
J)dh~
Dale F. Shug a t
Supreme Court I_D_
35 East High Stree
Carlisle, PA 17013
(717) 241-oBll
203
Papers may be served at the address set
Attorney for Maria E. Verdekal
Date: September 4, 2003
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LAWRENCE L. VERDEKAL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003-3726 CIVIL TERM
vs.
IN DIVORCE:
MARIA E. VERDEKAL,
Defendant
PRAECIPE AND RULE FOR
BILL OF PARTICULARS
TO THE PROTHONOTARY:
Dear Sir:
Please issue a Rule on Plaintiff to file a Bill of particulars
in regard to Count II of the Complaint, alleging adultery and
indignities (Sections 3301 (a) (2) and (6) of the Divorce Code)
within twenty (20) days after service of the Rule, or Non Pros.
Sec. Leg.
o<)&e F
Dale F. Shughar , J .
Supreme Court 1. D . 93 'Z
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-.D11
Attorney for Maria E. Verdekal
RULE
AND NOW, this 1~ day of September, 2003, a Rule is entered
upon the Plaintiff Lawrence L. Verdekal, Jr., as above.
rothonotary
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LAWRENCE L. VE DEKAL, JR.
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003- 3726 CIVIL TERM
MARIA E. VERDE L,
Defendant
CIVIL ACTION-lAW
IN DIVORCE
BILL OF PARTICULARS
AND NOW, mes Lawrence L. Verdekal, Jr., the Plaintiff, by and through his
attorney, Michael A. Scherer, Esquire, and respectfully submits this Bill of Particulars in
support of Count II i the divorce complaint setting forth the grounds of adultery.
1. The d fendant, Maria E. Verdekal, is pregnant with a child whom she has
2. intiff is in possession of various written notes between Maria
admitted was not fat ered by the Plaintiff and was conceived during Plaintiffs
deployment in Afgh nistan prior to the parties' separation.
Verdekal and Josh vels, a soldier she had an affair with at Fort Campbell, Kentucky,
which notes tend to how a sexual relationship.
3. The PI intiff is in possession of pictures taken of Maria Verdekal and Josh
Bevels in amorous p sitions and it is believed the photographs were taken while
Plaintiff was in Afgha istan.
Respectfully submitted,
O'BRI~~~RER
Michael A. Scherer, Atty for Plaintiff
I.D.# 61974
17 West South Street
Carlisle, PA 17013
(717) 249-6873
mas.dir/domestic/verde al/billofpart.wpd
VERIFICATION
I verify tha the statements made in this Bill of Particulars are true and correct.
I understand that alse statements herein are made subject to the penalties of 18 Pa.
C.S. S 4904, relat ng to unsworn falsification to authorities.
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LAWRENCE L. VERDEKAL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003-3726 CIVIL TERM
vs.
IN DIVORCE
MARIA E. VERDEKAL,
Defendant
ANSWER TO BILL OF PARTICULARS
AND NOW, comes Maria E. Verdekal, the Defendant, by and
through her attorney, Dale F. Shughart, Jr., Esquire, and
respectfully answers the Bill of particulars filed by the
Plaintiff, Lawrence L. Verdekal, Jr, as follows:
1. Denied. It is specifically denied that the Defendant,
Maria E. Verdekal, became pregnant while Plaintiff, Lawrence L.
Verdekal, Jr. was deployed in Afghanistan.
On the contrary,
Defendant did not have sexual relations with anyone other than her
husband during their marriage and prior to his filing of the above
captioned Divorce action on August 1, 2003.
2 .
Denied.
While Plaintiff was deployed in Afghanistan,
Defendant was at Fort Campbell, Kentucky and resided with a
roommate, Jackie Gruntz. She was introduced to a friend of Jackie
Gruntz's named Josh Bevels approximately one week before he was
deployed in Afghanistan.
The Defendant corresponded with Josh
Bevels as a "military pen pal" while he and the Plaintiff were both
deployed in Afghanistan. To the best of Defendant's knowledge Josh
Bevels is still deployed in Afghanistan. Letters written between
the Defendant and Josh Bevels are not indicative of a sexual
relationship.
In fact, no sexual relationship did or does exist
between them.
3 .
Denied.
As stated above, Defendant met Josh Bevels at
Fort Campbell, Kentucky approximately one week before his
deployment to Afghanistan.
If pictureB do exist, they were
apparently taken by Jackie Gruntz. Any photographs which appear to
depict the Defendant and Josh Bevels in an "amorous position" have
been altered to depict something which did not occur.
JJ~/
Dale F. Shughar J.
Supreme Court I.D. 93 3
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Attorney for Maria E. Verdekal
VERIFICATION
I, Maria E_ Verdekal, verify that the statements made in this
Answer to Bill of Particulars are true and correct. I understand
that false statements herein are made subject to penalties of 18
Pa.C.S.!l4904, relating to unsworn falsification to authorities.
Date: NovemberOl.I,2003
A-{~ ~~YC{Adc~
Maria :. Verdekal
LAWRENCE L. VERDEKAL, JR_,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003..3726 CIVIL TERM
MARIA E. VERDEKAL,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 26th day of November, 2003, I, Dale F. Shughart,
Jr., attorney for Defendant, Maria Verdekal, hereby certify that I
have served a copy of the Answer to Bill of Particulars by mailing
a copy of the same by United States mail, postage prepaid,
addressed as follows:
Michael A. Scherer, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, PA 17013
Dale F. Shug art
Supreme Court I.D.
35 East High Stree
Carlisle, PA 1701
203
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LAWRENCE L. VERDEKAL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003- 3726 CIVIL TERM
CIVIL ACTION-U\W
IN DIVORCE
V.
MARIA E. VERDEKAL,
Defendant
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PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE
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1. A complaint in divorce under Section 3301 (C) of the Divorce Code was
filed on August 1, 2003.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree in divorce without notice.
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4. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them b,~fore a divorce is granted.
5. I understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is filed
with the Prothonotary.
6. I have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
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I Date: July 2. 'f ,2005
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C.7 LAWRE L. VERDEKAL, JR.
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I~ THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PE.'lNSYLVANIA
LAWRENCE L. VERDEKAL, JR.,
Plaintiff
Plaintiff
NO. 2003-3726 CIVIL TERM
vs.
IN DIVORCE
MARIA E. VERDEKAL,
Defendant
~xxxxxxxxxxxxxxxxxxxx~
XOTION FOR APPOI?clTIlENT OF XASTER
Lawrence L. Verdekal, Jr. (Plaintiff) (RBUXamllIxar), moves the court to appoint
a master with respect to the following claims:
(X) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
(
(
(
(
)
)
)
)
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in support or the motion states:
(1) Discovery is complete as to the claims('8
appointment or a master is requested.
(2) The defendant (has) ~x=9 alllleared in
Dale F. Shughart, Jr. ."
The staturory ground~ ror divorce (is)
for ~Nhich the
(by his attorney,
(3)
the action ~R~
,Esquire) .
~~* divorce
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims: none
(c) The action is contested with respect :0 the following
claims: divorce
(5) The action (~~lVU) (does not involve) complex issues or law
or fact.
(6) The hearing is e.."'qJected to take 3 (hours) ~x.
(7) Additional inio!:Jla:cion, .~ any. relevant to the motion:
~~
Date:
M fM"l/~ 1&, Z-.9.9(,
Atto?ffr:f fO~intiff)
~li~
ORDER APPOI?clTING )L~STER
~~ NOW ,19____
is appointed master with respect to the following claims:
Esquire,
By the Court::
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I~ THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYlVANIA
LAWRENCE L. VERDEKAL, JR.,
Plaintiff
Plaintiff
NO. 2003-3726 CIVIL TERM
vs.
IN DIVORCE
MARIA E. VERDEKAL,
Defendant
~xxxxxxxxxxxxxxxxxxxx~
:lOTION FOR APPOI~TI1ENT OF :l.'\.STER
Lawrence L. Verdekal, Jr. (Plaintiff) (Rll<li<ecJxI.xxlZ:), moves the court to appoint
a master with respect to the following claims:
(X) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
(
(
(
(
)
)
)
)
Distribution of Property
Support
Counsel Fees
Costs and L~penses
and in support of the motion states:
(1) Discovery is complete as to the claims (~ for ."hich the
appointment of a master is requested.
(2) The defendant (has) ~X=9 appeared in
Dale F. Shughart, Jr.
The staturory ground~ for divorce (is)
(by his attorney,
(3)
the action ~R~
,Esquire) .
~~ divorce
following claims:
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
none
(c) The action is contested with respect to the following
claims: divorce
(5) The action (~~~g) (does not involve) complex issues or law
or fact.
(6) The hearing is e.""qlected to take 3 (hours) ~x.
(7) Additional information, .~ any. relevant to the motion:
~~
Date:
MMvlr 1&.l--9.:J1.,
Att?!lf:! fO~"1tiff)
QoeJflU[~
ORDER APPOI~TING :iASTER
_-\J.'ID NOW fY}CUI'A tJ"t ,~~ C 6-t'NL ~;lLt'..h/! ff
is appointed master with respect to the following claims: /JlA ~//
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Esquire,
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LAWRENCE L. VERDEKAL, JR. :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2003-3726
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF SERVICE
II I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce
!'
action, do hereby certify that I served a certified copy of the Complaint in Divorce to the
I Defendant, as per the attached U.S. Postal Service Certified Mail return receipt card.
II
:
O'BRIEN, BARIC & SCHERER
1fUfv-
Michael A. Scherer, Esquire
I
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II DATE: March 30, 2006
II
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Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
manE- t 0 ~HdtKa\
-3\\ ~f.rr~\j-ll\E- RDad
tarlislt..) fA 110\3
2. Article Number
(Transfer from service label)
PS Form 3811. August 2001
o Agent
Addressee
Mrr of D~iYel!':~':
D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
\.
3. irvice Type
Certified Mail
Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
o C.O.D.
4. Restricted Delivery? (Extra Fee)
7002 0860 0000 1077 7276
Domestic Return Receipt
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Postage $
Certified Fee
Return Receipt Fee
o (Endorsement Required)
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cO Restricted Delivery Fee
o (Endorsement Required)
Total Po8tage & Fees
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LAWRENCE L. VERDEKAL, JR. :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2003-3726
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MOTION TO VACATE MASTER'S APPOINTMENT
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1. Movant is Michael A. Scherer, Esquire, attorney for Plaintiff in the above-
captioned matter.
2. On or about March 30, 2006, the Honorable Edgar B. Bayley appointed E.
Robert Elicker, II as Divorce Master.
3. Subsequent to Master's appointment, the parties negotiated a settlement.
WHEREFORE, Movant respectfully requests that the Master's appointment be vacated.
By
Respectfully submitted,
~JJlEN, BARIC & SCHERER
tllfff~
Michael A. Scherer, Esquire
Attorney for Plaintiff
l.D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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LAWRENCE L. VERDEKAL, JR. :
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003- 3726 CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was
filed on August 1, 2003.
2. Defendant acknowledges receipt and accepts service of the Complaint on
August 5, 2003 by certified mail.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
4. I consent to the entry of a final decree in divorce without notice.
5. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
6. I understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is filed
with the Prothonotary.
7. I have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: /V\A t2t...H ZLj :+oC6
rl~Q G0-. C .v~l,J-€t~)
Maria E. Verdekal
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BY:
LAWRENCE L. VERDEKAL, JR. :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2003-3726
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
, ~ OF COURT
AND NOW, this ~ay clf~,'2006, upon review of the attached Motion filed by
Michael A. Scherer, Esquire, Attorney for Plaintiff in the above-captioned action the
appointment of E. Robert Elicker, II as Divorce Master is hereby VACATED.
BY THE COURI~
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LAWRENCE L. VERDEKAL, JR. :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2003-3726
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MOTION TO VACATE MASTER'S APPOINTMENT
1. Movant is Michael A. Scherer, Esquire, attorney for Plaintiff in the above-
captioned matter.
2. On or about March 30, 2006, the Honorable Edgar B. Bayley appointed E.
Robert Elicker, II as Divorce Master.
3. Subsequent to Master's appointment, the parties negotiated a settlement.
WHEREFORE, Movant respectfully requests that the Master's appointment be vacated.
By
Respectfully submitted,
~;'f;::IC & SCHERER
Michael A. Scherer, Esquire
Attorney for Plaintiff
1.0. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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I LAWRENCE L. VERDEKAL, JR.
I Plaintiff
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MARIA E. VERDEKAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003-3726
CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Service was made via USPS Certified
Mail on August 6, 2003.
3. (complete either paragraph (a) or (b).)
A. Date of execution of the affidavit of consent required by Section 3301 (c)
of the Divorce Code: by Plaintiff on July 29, 2005; and Defendant on March 24, 2006.
B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301(d)
of the Divorce Code: N/A
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(2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce
Code: None.
Respectfully submitted,
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Michael A. Scherer, Esquire
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LAWRENCE L. VERDEKAL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2003-3726
CIVIL TERM
MARIA E. VERDEKAL,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
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PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
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1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce
Code.
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2. Date and manner of service of the Complaint: Service was made via USPS Certified
Mail on August 6, 2003.
3. (complete either paragraph (a) or (b).)
A. Date of execution of the affidavit of consent required by Section 3301 (c)
of the Divorce Code: by Plaintiff on July 29, 2005; and Defendant on March 24, 2006.
B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301 (d)
of the Divorce Code: N/A
(2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce
Code: None.
Respectfully submitted,
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Michael A. Scherer, Esquire
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: IN THE COURT OF COMMON PLEAS :
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: OFCUMBERLANDCOUNTY :
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: STATE OF PENNA. :
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. LAWRENCE L. VERDEKAL, JR., .
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: No. 2003 - 3726 CIVIL:
: Plaintiff, :
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+. VERSUS +.
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. MARIA E. VERDEKAL, .
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: Defendant. :
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: DECREE IN :
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: DIVORCE :
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: AND NOW, ~ {It"; \~ , J"Cl()l,o, IT IS ORDERED AND :
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: DECREED THAT LAWRENCE L. VERDEKAL, JR. , PLAINTIFF, :
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: AND MARIA E. VERDEKAL :
+. ' DEFENDANT, +.
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. ARE DIVORCED FROM THE BONDS OF MATRIMONY. .
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: THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE :
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. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A F'INAL ORDER HAS NOT .
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: YET BEEN ENTERED; :
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. NONE. .
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: BnHE COU"T, tJ; :
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