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HomeMy WebLinkAbout04-4567LAWRENCE L. VERDEKAL, ,JR.: Plaintiff MARIA E. VERDEKAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2004- ~4"(,, ~7 CIVIL TERM CIVIL ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY The Plaintiff is Lawrence L. Verdekal, Jr., an adult individual who resides at Fort Campell, Kentucky, with a mailing address of P.O. Box 935. Fort Campbell, Kentucy 42223. The Plaintiff is currently on active duty in the United States Army, 2. The Defendant is Maria E, Verdekal, an adult individual residing at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present residence Age Dylan N. Verdekal 4830 East Trindle Road 2 Mechanicsburg, Pennsylvania The child's birth date is October 26, 2001. The child was born out of wedlock. The child is presently in the custody of Defendant, who resides at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Maria E. Verdekal Kirk McBeth Maria E. Verdekal Heather Moore Residences Dates 4830 East Trindle Road Mechanicsburg, Pennsylvania August 2004 to Present 2507 Warren Way Mechanicsburg, Pennsylvania August 2003 to August 2004 Maria E. Verdekal Kelly Shover George Warrell Lawrence L. Verdekal Maria E. Verdekal Lawrence L. Verdekal Maria E. Verdekal 159 Cottage Road Shippensburg, Pennsylvania March 2003 to August 2003 Ft. Campbell, Kentucky July 2002 to March 2003 389 Pin Oak Lane Carlisle, Pennsylvania October 2001 to July 2002 The natural mother of the child is Maria E. Verdekal, currently residing at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. She is married to the Plaintiff. The natural father of the child is Lawrence L. Verdekal, Jr. who resides at Fort Campbell, Kentucky, and whose domicile is 1576 Newville Road, Carlisle, Cumberland County, Pennsylvania. He is married to the Defendant. 4. The relationship of the Plaintiff to the child is that of natural father. The plaintiff currently resides with the following persons: Names Relationship NONE 5. The relationship of the Defendant to the child is that of natural mother. The defendant currently resides with the following persons: Names Relationship Kirk McBeth Boyfriend 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pendir in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene, WHEREFORE, Plaintiff requests your Honorable Court to grant him partial physical custody of the child for six (6) months and fifteen (15) days per year. DATE: Respectfully submitted, O'BRIEN, BARIC & SCHERER ~rer, Esquire I.D, #61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dirldomesticlverdekallcustody.com VERIFICATION The statements in the foregoing Complaint For Custody are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. ~ Lawr~m~e' ' ,--b. Verdekal, Jr. LAWRENCE L. VERDEKAL, JR. PLAINTIFF V. MARIA E. VERDEICA. L DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-4567 CiViL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 23, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre J_acqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 19, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children a~e five or older may also be l~resent at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infbrmation about accessible l~cilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All an'angements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 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, Pennsylvania 17013 Telephone (717) 24%3166 LAWRENCE L. VERDEKAL, JR.: Plaintiff MARIA E. VERDEKAL, Defendant $£P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2004- qS,~? CIVILTERM CIVIL ACTION-LAW IN CUSTODY ORDER OF COURT AND NOW THIS day of , ,2004, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at on the __dayof ,2004 at A.M./P.M., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT, BY Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GE']" LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 LAWRENCE L. VERDEKAL, JR.: Plaintiff MARIA E. VERDEKAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004- ~5"(,,") CIVIL TERM CIVIL ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY The Plaintiff is Lawrence L. Verdekal, Jr., an adult individual who resides at Fort Campell, Kentucky, with a mailing address of P.O. Box 9,"15, Fort Campbell, Kentucy 42223. The Plaintiff is currently on active duty in the United States Army. 2. The Defendant is Maria E. Verdekal, an adult individual residing at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present residence Age Dylan N. Verdekal 4830 East Trindle Road 2 Mechanicsburg, Pennsylvania The child's birth date is October 26, 2001. The child was born out of wedlock. The child is presently in the custody of Defendant, who resides at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Maria E. Verdekal Kirk McBeth Maria E. Verdekal Heather Moore Residences 4830 East Trindle Road Mechanicsburg, Pennsylvania 2507 Warren Way Mechanicsburg, Pennsylvania Dates August 2004 to Present August 2003 to August 2004 Maria E. Verdekal Kelly Shover George Warrell Lawrence L. Verdekal Maria E. Verdekal Lawrence L. Verdekal Maria E. Verdekal 159 Cottage Road Shippensburg, Pennsylvania March 2003 to August 2003 Ft. Campbell, Kentucky July 2002 to March 2003 389 Pin Oak Lane Carlisle, Pennsylvania October 2001 to July 2002 The natural mother of the child is Maria E. Verdekal, currently residing at 4830 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. She is married to the Plaintiff. The natural father of the child is Lawrence L. Verdekal, Jr. who resides at Fort Campbell, Kentucky, and whose domicile is 1576 Newville Road, Carlisle, Cumberland County, Pennsylvania. He is married to the Defendant. 4. The relationship of the Plaintiff to the child is that of natural father. The plaintiff currently resides with the following persons: Names Relationship NONE 5. The relationship of the Defendant to the child is that of natural mother. The defendant currently resides with the following persons: Names Relationship Kirk McBeth Boyfriend 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff requests your Honorable Court to grant him partial physical custody of the child for six (6) months and fifteen (15) days per year. DATE: Respecffully submitted, O'BRIEN, BARIC & SCHERER I~li(~hael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dirldomesticlverdekallcustody.com VERIFICATION The statements in the foregoing Complaint For Custody are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. ~ Law r~W~b"e b. Verdekal, J~, (9? © LAWRENCE L. VERDEKAL, JR. PLAINTIFF V. MARIA E. VERDEKAL DEFENDANT iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 04-4567 CIVIL ACTION LAW : : IN CUSTODY ORDER OF (7()[IRT AND NOW, Thursday, September 23, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre Jacqueline M. Verney, Esq.__, the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 19, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be, made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be 0resent at the conference. Failure to appear at the conference may provide grounds for entry ora temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ facqueline M. Verney, Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 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 Assoc, iation 32 South Bedford Street Carlisle, Pennsylvania 170][3 Telephone (717) 249-3166 ,4'5' ¥ OCT Vm MARIA E. VERDEKAL, Defendant LAWRENCE L. VERDEKAL, JR.,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-4567 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Lawrence L. Verdekal, Jr., and the Mother, Maria E. Verdekal, shall have shared legal custody of Dylan N. Verdekal, bom October 26, 2001. Each party shall have an equal right, to be exercised jointly with the other party, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. follows: Father shall have periods of partial physical custody of the Child as A. October 19, 2004 from 12:00 noon to 7:30 p.m. B. Thanksgiving from November 25, 2004 at 3:00 p.m. to Sunday, November 28, 2004 at 9:00 a.m. C. Seven days over the Christmas holiday as agreed by the parties. As part of Father's seven day period he shall have physical custody of the child on Christmas Eve until 10:00 p.m. and Mother shall have physical custody of the child from Christmas Eve at 10:00 p.m. through Christmas Day. D. Such other times as the parties agree. 4. Father shall be responsible for transportation. 5. Father shall call the child once per week. Mother shall have liberal telephone contact with the child when the child is in Father's custody. 6. Neither party shall do anything nor permit a third party to do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. 7. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Tuesday, January 18, 2005 at 8:30 a.m. cc~iichael A. Scherer, Esquire, Counsel for Father Jessica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother MARIA E. VERDEKAL, Defendant LAWRENCE L. VERDEKAL, JR.,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : 2004-4567 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCII JATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Dylan N. Verdekal DATE OF BIRTH October 26, 2001 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on October 19, 2004, with the following individuals in attendance: Father, Lawrence L. Verdekal, Jr., with his counsel, Michael A. Scherer, Esquire and Maria E. Verdekal, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The parties agreed to the entry of an Order in the form as attached. Date gacqffeline M. Vemey, Esquire Custody Conciliator JAN , c. i;;j ccoc3- r / ~uUJ \) LAWRENCE L. VERDEKAL, JR.,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-4567 CIVIL TERM MARIA E. VERDEKAL, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT r\^ ~ AND NOW, this JO day of ,2005, upon consideration of the attached Custody Con iation Report, it is ordered and directed as foHows: I. The prior Order of Court dated October 22, 2004 is hereby vacated. 2. The Father, Lawrence L. Verdekal, Jr., and the Mother, Maria E. Verdekal, shaH have shared legal custody of Dylan N. Verdekal, born October 26, 2001. Each party shaH have an equal right, to be exercised jointly with the other party, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. Mother shall have primary physical custody of the Child. 4. follows: Father shall have periods of partial physical custody of the Child as A. The Easter holiday from Friday at 12:00 noon to Sunday at 12:00 noon, provided Father is in the area. B. One uninterrupted week in the summer, provided Father gives Mother thirty days prior notice. C. Thanksgiving from the Wednesday before Thanksgiving at 3:00 p.m. to the Sunday after Thanksgiving at 9:00 a.m. D. Seven days over the Christmas holiday as agreed by the parties. As part of Father's seven day period he shaH have physical custody of the child on Christmas Eve until 10:00 p.m. and Mother shall have physical custody ofthe child from Christmas Eve at 10:00 p.m. through Christmas Day. E. If Father is in the area, from Friday to Sunday at times agreed by the parties, provided Father give Mother one week notice. F. Such other times as the parties agree. 5. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day at times agreed by the parties. 6. Paternal Grandparents may have physical custody of the child one weekend per month at times as agreed by Mother and Grandparents. 7. The child is to have no contact with Jessica Shover. 8. Mother shall obtain a speech evaluation for the child. 9. Father or his family shall be responsible for transportation. 10. Father shall call the child once per week. Mother shall have liberal telephone contact with the child when the child is in Father's custody. II. Neither party shall do anything nor permit a third party to do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. 12. This Order is entered pursuant to an agreement ofthe parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. . cc: Michael A. Scherer, Esquire, Counsel for Father ~ ~ Jessica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother /. ..2/-(.1 s' ~ Ze ,(' i. '...', .. ~.~ 'v 0',' ""~ ',,'" . v ll{i.:j SUJ':' , ! '\]5 :r LAWRENCE L. VERDEKAL, JR.,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-4567 CIVIL TERM MARIA E. VERDEKAL, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dylan N. Verdekal October 26, 2001 Mother 2. A Conciliation Conference was held in this matter on January 18,2005, with the following individuals in attendance: Father, Lawrence L. Verdekal, Jr.'s counsel, Michael A. Scherer, Esquire with paternal grandfather, and Maria E. Verdekal, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated October 22,2004 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody. 4. The parties agreed to the entry of an Order in the form as attached. , -f'! .{/.> Date i , 'Vi ( c... -.....L-.''-_","--" I \ V l<----.......v...- cq line M. Verney, Esquire Custody Conciliator