Undue Influence to challenge a Will or Power of Attorney

A grievance based upon undue influence may be sustained by showing that

the beneficiary had a confidential relationship with the party who established the
account. Accordingly, if the challenger can prove by a preponderance of the
evidence that the survivor had a confidential relationship with the donor who
established the account, there is a presumption of undue influence, which the
surviving donee must rebut by clear and convincing evidence.
[Estate of Ostlund v. Ostlund, 391 N.J. Super. 390, 401 (App. Div. 2007).]
Although perhaps difficult to define, the concept "encompasses all relationships
'whether legal, natural or conventional in their origin, in which confidence is
naturally inspired, or, in fact, reasonably exists. Pascale v. Pascale, 113 N.J. 20, 34
(1988) (internal citation omitted). "And while family ties alone may not qualify,
parent-child relationships have been found to be among the most typical of
confidential relationships." DeFrank, supra, slip op. at 13 (citing Ostlund, supra,
391N.J. Super. at 401).
In the context of inter vivos gifts, "a presumption of undue influence arises when
the contestant proves that the donee dominated the will of the donor or when a
confidential relationship exists between the donor and done." Pascale, supra,
113 N.J. at 30 (internal citations omitted). "Where parties enjoy a relationship in
which confidence is naturally inspired or reasonably exists, the person who has
gained an advantage due to that confidence has the burden of proving that no
undue influence was used to gain that advantage," In re Estate of Penna,322 N.J.
Super. 417, 423 (App. Div. 1999), and "the donee has the burden of showing by
clear and convincing evidence not only that 'no deception was practiced therein, no
undue influence used, and that all was fair, open and voluntary, but that it was well
understood.'" In re Estate of Mosery, 349 N.J. Super. 515, 522-23 (App. Div. 2002)
(citing In re Dodge, 50 N.J. 192, 227 (1967)).
The person receiving gifts and greater benefit had a burden to show no deception
was practiced and that all of the transactions were fair, open and voluntary, and
that they were well understood.
One of the major cases dealing with undue influence was Haynes v. First
National State Bank of New Jersey, 87 N.J. 163, 75-76 (1981). Here the Supreme
Court held that the burden of proof establishing undue influence shifts to the
proponent when a will benefits a person who stood in a confidential relationship
to the decedent and there are suspicious circumstances, which need
explanation. The suspicious circumstances need only be slight. Id. at 176.
Moreover, when the evidence is almost entirely in the possession of one party
and the evidence points to the proponent as asserting undue influence, a clear
and convincing standard may be applied rather than the normal burden of proof
of preponderance of the evidence. Id. at 183.

Furthermore, the Haynes analysis was extended to situations in which

there is a transfer of property where the beneficiary of the property and an
attorney is on one side and the donor on the other. See Oachs v. Stanton, 280
N.J. Super. 478, 483 (App. Div. 1995).
The court in Oachs determined that under circumstances such as these the
donee bears the burden of proof to establish the validity of the gift, even in
situations in which the donee did not dominate the decedents will. Id. at 485.
This rule was established to protect a donor from making a decision induced by a
confidential relationship the donee possesses with the donor. Id. Again, the
burden is a clear and convincing standard. Id.
The Supreme Court in Pascale v. Pascale, 113 N.J. 20, 31 (1998), stated
that when a donor makes a gift to a donee that he/she is dependent upon, a
presumption arises that the donor did not understand the consequences of
his/her act. In these situations the donee must demonstrate that the donor had
disinterested and competent counsel. Id. Likewise, undue influence is conclusive,
when a mentally or physically weakened donor makes a gift without advice or a
means of support, to a donee upon whom he/she depends. Id.
A confidential relationship can be found to exist when one is certain that
the parties dealt on unequal terms. In re Stromings Will, 12 N.J. Super. 217, 224
(1951). The appropriate inquiry is if a confidential relationship existed, did the
parties deal on terms and conditions of equality? Blake v. Brennan, 1 N.J. Super.
446, 453 (1948).
Suspicious circumstances are not required to create a presumption of
undue influence with regard to inter vivos gifts and the presumption of undue
influence is more easily raised in an inter vivos transfer. See Pascale, supra, 113
N.J. at 31; Bronson v. Bronson, 218 N.J. Super. 389, 394 (App. Div. 1987).
Generally, an adult is presumed to be competent to make an inter vivos
gift. See Conners v. Murphy, 100 N.J. Eq. 280, 282 (E. & A. 1926); Pascale v.
Pascale, 113 N.J. 20, 29 (1988). However, when a party alleges undue influence
with regard to an inter vivos gift, the contesting party must prove undue
influence existed or that a presumption of undue influence should arise. Pascale,
supra, 113 N.J. at 30.

A presumption of undue influence arises when a confidential relationship

exists between the donor and donee or where the contestant proves the donee
dominated the Will of the donor. Id.; see also Seylaz v. Bennett, 5 N.J. 168, 172
(1950); In re Dodge, 50 N.J. 192, 227 (1967); Mott v. Mott, 49 N.J. Eq. 192, 198
(Ch. 1891); Oachs v. Stanton, 280 N.J. Super. 478 (App. Div. 1995) (holding that
where a confidential relationship existed and that the donor did not rely upon the
donee, a shifting of the burden was still appropriate); In re Neumans Estate, 133
N.J. Eq. 532, 534-35 (E. & A. 1943) (stating in a will context Such burden does
not shift merely because of the existence of a confidential relationship, without
more, as in the matter of gifts inter vivos.)
The In re Dodge court explained why a presumption of undue influence
arises in a confidential relationship and stated: In the application of this rule it is
not necessary that the donee occupy such a dominant position toward the donor
as to create an inference that the donor was unable to assert his will in
opposition to that of the donee. In Re Dodge, 50 N.J. 192 (1967). The court
referenced a much earlier case in explaining the rules application:
"Its purpose is not so much to afford protection to the donor against the
consequences of undue influence exercised over him by the donee, as it is to
afford him protection against the consequences voluntary action on his part
induced by the existence of the relationship between them, the effect of which
upon his own interests he may only partially understand or appreciate." In re
Dodge, supra, 50 N.J. at 228 citing Slack v. Rees, 66 N.J. Eq. 447, 449 (E. & A.
1904).
In sum, once it is proven that a confidential relationship exists the burden
shifts to the donee to show by clear and convincing evidence that no undue
influence was used. Although the case law indicates suspicious circumstances
need not be shown the donee must show all was fair, open and voluntary, no
deception was practiced and that the transaction was well understood. Pascale,
supra, 113 N.J. at 31; see also In re Dodge, supra, 50 N.J. at 227; Seylaz, supra, 5
N.J. at 173. Furthermore, confidential relationships arise in all types of
relationships whether legal, natural or conventional in their origin, in which
confidence is naturally inspired, or, in fact, reasonably exists. In re Fulpers
Estate, 99 N.J. Eq. 292, 314 (Prerog. Ct. 1926); see Pascale, supra, 113 N.J. at 34.
It appears confidential relationships exist in all cases in which:
"The relations between the [contracting] parties appear to be of such a
character as to render it certain that they do not deal on terms of equality, but
that either on the one side from superior knowledge of the matter derived from a
fiduciary relation, or from over-mastering influence; or on the other from

weakness, dependence or trust justifiably reposed, unfair advantage is rendered

probable." Pascale, supra, 113 N.J. at 34, quoting In re Fulper, supra, 99 N.J. Eq.
at 314; see also In re Dodge, supra, 50 N.J. at 228.
In determining whether the Defendant was the dominant person in the
relationship there is no clear-cut rule and instead the court must look to the
particular circumstances of the matter. In re Fulper, supra, 99 N.J. Eq. at 315;
Giacobbi v. Anselmi, 18 N.J. Super. 600, 616 (Ch. Div. 1952). In Fulper the court
determined that a confidential relationship existed in a father-son relationship in
which the father was advanced in age, weak and physically depended upon the
son. Moreover, since the father sought the sons assistance on business matters,
lived with the son during the winter months and gave the son joint and several
power over his checking account an actual repose of trust and confidence in the
son was demonstrated. In re Fulper, supra, 99 N.J. Eq. at 318.
In the Giacobbi case, supra, a confidential relationship was determined to
exist between a mother and daughter, even though the mother did not suffer
from mental or physical infirmity. There the mother was found to be alert, active,
and somewhat independent. However, she turned to the daughter for small
issues and problems when they occurred. Giacobbi, supra, 18 N.J. Super. at 617.
Therefore, the burden can shift to Defendant to prove by clear and
convincing evidence the transaction was not unduly influenced. Furthermore,
where a donor makes an improvident gift to the donee upon whom she
depends that strips the donor of all or virtually all their assets, as here, a
presumption arises that the donor did not understand the consequences of their
act. Pascale, supra, 113 N.J. at 31, citing Vanderbach v. Vollinger, 1 N.J. 481, 489
(1949). Under those circumstances the donee must establish that the donor had
the advice of competent and disinterested counsel. Id. citing Vanderback, supra,
1 N.J .at 488-89.
Similarly, when a mentally or physically weakened donor makes a gift to a
donee whom the donor is dependent upon, without advice, and the gift leaves
the donee without adequate means of support, a conclusive presumption of
undue influence arises. Id. citing Seylaz, supra, 5 N.J. at 173. However, when a
donor is not dependent upon the donee independent advice is not a
prerequisite to the validity of an improvident gift even though the relationship
between the parties is one of trust and confidence. Id. citing Seylaz, supra, 5
N.J. at 173.

Although suspicious circumstances are not required to be established in an

inter vivos transfer for a presumption of undue influence to exist, thereby
shifting the burden of proof, Plaintiff has raised the issue. Pascale, supra, 113 N.J.
at 30.
If Undue Influence was 'Clear,' the Will of the Elderly Testatrix is
Denied Admission to Probate.
The testatrix's Will was properly rejected as the product of undue influence
because the proponent and the testatrix had a confidential relationship and
because there were "suspicious circumstances" surrounding the execution of the
will.
In Re Probate of the Last Will and Testament of Catelli 361 NJ Super. 478 (App.
Div. 2003)
In the Catelli case, Thomas R. Villone was named by his elderly aunt,
Anna Villone Catelli, as the executor in a will and as the trustee under a living
trust, which she executed on January 9, 1996. He appeals from the decision of the
Chancery Division which refused to admit that 1996 will to probate, which named
his cousin, George Villone, as the Administrator C.T.A. of Catelli's estate, which
ordered him to restore assets to the estate, which awarded counsel fees and
which dismissed a related complaint that he had filed in his effort to enforce
certain provisions of the 1996 trust.
The decision of the trial court was made following two days of testimony
and the consideration by the court of deposition testimony given by witnesses,
including Thomas Villone, who could not appear in New Jersey. In that decision,
the court first held that, as a matter of public policy, the will could not be
admitted to probate because at the time of the execution of the 1996 will, Anna
Catelli had become blind and the only person who could verify that the contents
of the documents had been read to her so that she knew what she was signing
was Thomas, who the disputed documents made her sole heir. As an alternate
ground, the judge analyzed the testimony and the evidence in the nature of an
application for a directed verdict at the close of the plaintiff's case and
determined that Thomas Villone could not prevail on the merits. Because we
affirm the decision of the court based upon the alternate ground, we do not
address the court's public policy rationale.
Viewed in the light most favorable to Thomas Villone, the record discloses
the following facts. The testator, Anna Catelli, was a widow who had no children
and who lived alone. She had a number of nieces and nephews, including Thomas
Villone and George Villone. She also had a brother, Robert, who died in Florida in
1994. Robert had named Thomas, his nephew, as the executor and principal
beneficiary of his estate. Thomas, who was a self- employed long distance truck
driver living in Arizona, had not had much contact with Anna Catelli, but
telephoned to tell her of her brother's death. In that conversation, Catelli had
asked him to come and visit her when he was next in New Jersey and he
thereafter did so.
Early in 1994, while Thomas was visiting her at her home, then in
Springfield, Catelli asked him to drive her to her lawyer's office in Maplewood,

which he did. He learned that day that Catelli had named him as her alternate
power of attorney in the event that her long-time physician and confidante, Dr.
Coppola, was unable to serve. While he was not aware of it at the time, she had
gone to the lawyer's office that day to execute a will that left her estate to a
variety of relatives and friends and to two churches and which included him as
one of the residuary beneficiaries. Later that year, Catelli suffered a significant
stroke which left her partially paralyzed and with limited powers of speech and
sight. She was moved by Dr. Coppola to a nursing home, and thereafter to the
Garden Terrace Nursing Home where she remained until her death. Thomas
visited her at the nursing home from time to time when he was in New Jersey.
Shortly before Thanksgiving 1995, Dr. Coppola telephoned Thomas and told him
that Catelli wanted to make him her sole heir. Dr. Coppola died two or three days
later.
Following Dr. Coppola's death, Thomas invoked the power of attorney to
make $10,000 gifts to himself, his wife and his daughter. He next received from
Dr. Coppola's son all of the papers relating to Catelli's assets. While Thomas then
knew that the designation of him as the sole heir was a departure from her earlier
will, he did not discuss this apparent change of plans with Catelli. Rather, he
immediately consulted an attorney in Arizona who prepared a living trust, which
named Thomas as the trustee, and a pour-over will which named Thomas as the
executor and sole heir. The Arizona attorney gave the documents to Thomas
along with a letter which instructed him to have the documents reviewed by a
New Jersey attorney and which suggested that Anna be represented by
independent counsel. Thomas then came to New Jersey, arriving on January 6,
1996. While Thomas knew that Catelli had been represented in the past by the
lawyer in Maplewood, he did not contact him and did not consult with any other
New Jersey lawyer. Instead, he went directly to the nursing home and visited with
Catelli.
Over the course of the next three days, while she remained in her bed
and dozed on and off, he read the documents to her. Thomas has a high school
education and concedes that he would not have been able to explain or interpret
any of the language of the trust or the will to Catelli. He was aware that the trust
and the will together would enable him to avoid probate, but he did not
understand why that might be advantageous. At no time did he suggest that
Catelli consult with an attorney or offer to contact her New Jersey lawyer for her.
After three days, Thomas made arrangements with the administrator
of the nursing home to execute the trust and the will. The administrator served as
a notary and two nurses observed Catelli place an "X" on the line Thomas
indicated. Shortly after the execution, Thomas gave up his truck driving job,
employed himself as the full-time manager of Catelli's assets and undertook to
gain control of Catelli's interest in Excelsior Realty Ltd. (Excelsior), a family real
estate venture, through the trust instrument. Prior to Catelli's death, Thomas'
efforts to gain control of her interest in Excelsior consisted of correspondence
with his cousin George Villone who was the General Partner of that venture.
George Villone refused to acknowledge the validity of the January 9, 1996 trust
agreement and refused to turn control of Catelli's interest in Excelsior over to
Thomas. He continued to refuse after Catelli's death on July 5, 1997. As a result,
in March 1999, Thomas instituted litigation, in his capacity as the executor of
Catelli's estate and as her heir, against George Villone and Excelsior to force a

transfer of Catelli's interest to him. That complaint was consolidated with the
action filed subsequently by Thomas in the Chancery Division, Probate Part
seeking to have the disputed will admitted to probate.
The judge elected to first receive evidence relating to whether the 1996
will should be admitted to probate. At the close of the evidence offered in favor of
the admission of the will, the trial court held, first, that Thomas Villone had failed
to demonstrate that Catelli knew the contents of the documents that she had
signed. Relying on Harris v. Vanderveer's Executor, 21 N.J. Eq. 561, 563 (E. & A.
1870), Hildreth v. Marshall, 51 N.J. Eq. 241, 250 (Prerog. Ct. 1893) and Day v. Day,
3 N.J. Eq. 549, 553-55 (Prerog. Ct. 1831), the judge rejected the will. While each
of these decisions includes a discussion of the effect of visual impairment on the
knowing execution of a will, each of them arose in the context of a dispute based
on allegations of undue influence.
Thus, while each of these precedents rejected a proffered will
executed by a testator with a significant visual or other impairment, none
requires proof of knowing execution beyond that specified by the statute. N.J.S.A.
3B:3-2; N.J.S.A. 3B:3-4. The judge, however, reasoned that although the will had
been executed in accordance with the statutory formalities, public policy
demands proof beyond compliance with the formalities of execution if the testator
can no longer see. He held that the will was invalid because there was no
evidence from anyone other than the sole beneficiary that the will had been read
to Catelli and that she knew what she was signing. He therefore created an
additional requirement for probate of a will executed by a visually impaired
person, citing public policy. We appreciate the trial judge's concern that a
testatrix with a severe visual impairment is ordinarily unable, without the
intervention of a neutral person, to determine if the will as drafted accurately
memorializes her testamentary instructions. The same, of course, is true of a
testator who cannot read by reason of illiteracy. But whether the statutory
provisions for the witnessing and execution of the wills of such testators should
be augmented to require that the pre-execution reading of the will to the testator
be by a disinterested person is, in our view, a matter within the province of the
Legislature.
The court held We are satisfied, at least in this case, that we need not
further consider that issue because, as the judge found, this record speaks so
clearly of undue influence. The trial judge addressed the alternate ground of
undue influence using the standard of a directed verdict at the close of plaintiff's
proofs. R. 4:37-2(b). He found that there was a confidential relationship between
the decedent and the beneficiary, that there were suspicious circumstances
surrounding the execution, that undue influence was therefore presumed, that
the burden to overcome the presumption therefore shifted to Thomas and that
the record before the court made it impossible for him to carry that burden. He
therefore refused to admit the will to probate, dismissed the complaint against
George Villone and Excelsior, admitted Catelli's 1994 will to probate, appointed
George Villone as the Administrator C.T.A., directed Thomas to restore assets to
the estate and approved fees and commissions. We agree with the judge's
alternate analysis of the probate dispute and we affirm on that ground.
Viewed in terms of undue influence, there can be no doubt about the
issues before us. The judge identified several factors that supported his analysis
of undue influence, including the fact that Thomas retained his own attorney to

prepare the documents, that he did so based only on the conversation with Dr.
Coppola and without any consultation with Catelli herself, that the documents
were markedly different from Catelli's prior will, that Catelli was very debilitated
and vulnerable, that the effect of the documents was an immediate vesting of
control of all assets in Thomas through the inter vivos trust document, and that
Thomas immediately upon the death of Dr. Coppola left his employment and by
means of the power of attorney began to pay himself a commission and
dispensed substantial gifts to himself and his immediate family, which bespoke
self-dealing even prior to the time of the execution of the disputed documents.
The court held: We concur with the judge's analysis of the effect of
these facts. First, Catelli was clearly not well. The nursing administrator who saw
her daily conceded that, while she had made progress in recovering from her
stroke, her level of functioning was seriously diminished. Her short-term memory
was significantly impaired. Her vision had deteriorated substantially. She required
total care by the staff at the nursing home, needing daily assistance with feeding,
bathing, and other basic needs. During the three days prior to the execution of
the document, she did not leave her room, but remained in bed, dozing from time
to time and barely communicating with anyone. While she was undoubtedly fond
of Thomas, who was virtually her only visitor after the death of Dr. Coppola, she
was especially vulnerable to his influence.
Moreover, Thomas acted in a manner, which made his intentions clear.
Even accepting as true his testimony that he learned from Dr. Coppola that Catelli
intended to make him her sole heir, his behavior proves that he acted so as to
overbear her will. He made no effort to discuss Catelli's intentions with her prior
to acting for his unilateral benefit. He knew that Catelli had an attorney in New
Jersey who had prepared at least one earlier will, but he deprived Catelli of the
opportunity to consult with him. He did so in spite of the urging of his personal
attorney from Arizona to have the documents reviewed by New Jersey counsel
and to give Catelli the benefit of independent legal advice. He knew as well that
the 1994 will left significant assets to the two churches and a hospital, left
numerous specific bequests to friends and to a few family members, and included
him only as one of the residuary beneficiaries. Nonetheless, he made no effort to
discuss with Catelli why all were to be rejected in favor of him alone.
Nor did he simply carry out the instruction that he be made her sole
heir. Instead, he used his own attorney to secure immediate control of her assets.
He knew that Catelli had not previously utilized a trust and he knew from his own
lawyer that a living trust with a pour-over will would give him control before
Catelli died. In fact as soon as he had the ability to exercise any control through
the power of attorney, he gave $30,000 in gifts to himself, his wife and his
daughter, an act well in excess of any prior expression of generosity by Catelli
and not one she authorized. Shortly thereafter, he embarked on a new career,
hiring himself to be the full time manager of her assets, in spite of his lack of any
relevant training or experience. Those acts are the behavior not of one with
Catelli's interests at heart, but of one bent on his own enrichment at her expense.
The law governing undue influence is well established. While we generally
presume that the testator is of sound mind and competent to execute a will,
Gellert v. Livingston, 5 N.J. 65, 71 (1950), even a will which on its face appears to
have been validly executed can be overturned upon a demonstration of undue
influence. Haynes v. First Nat'l State Bank, 87 N.J. 163, 175-76 (1981). Similarly,

an inter vivos transfer, as was this trust, is equally governed by the undue
influence analysis. In re Dodge, 50 N.J. 192, 227-29 (1967); see Pascale v.
Pascale, 113 N.J. 20, 29-31 (1988).
Undue influence is "defined as 'mental, moral or physical' exertion which
has destroyed the 'free agency of a testator' by preventing the testator 'from
following the dictates of his own mind and will and accepting instead the
domination and influence of another.'" Haynes v. First Nat'l State Bank, supra, 87
N.J. at 176 (quoting In re Neuman, 133 N.J. Eq. 532, 534 (E. & A. 1943)). Where
the will benefits one who enjoyed a confidential relationship with the testator,
and where there are suspicious circumstances surrounding the will, the law
presumes undue influence and the burden is upon the proponent of the will to
disprove the presumption. In re Rittenhouse's Will, 19 N.J. 376, 378-79 (1955).
The court held: The confidential relationship between Thomas and Catelli
is both plain and conceded. See Haynes v. First Nat'l State Bank, supra, 87 N.J. at
176; In re Estate of Hopper, 9 N.J. 280, 282 (1952). The suspicious circumstances
surrounding the will need only be "slight" to shift the burden of proof to the
proponent to overcome them. See In re Estate of Lehner, 70 N.J. 434, 436 (1976);
In re Blake's Will, 21 N.J. 50, 55-56 (1956).Once the burden has shifted, the will
proponent must overcome that presumption by a preponderance of the evidence.
Haynes v. First Nat'l State Bank, supra, 87 N.J. at 177-78; In re Estate of Weeks,
29 N.J. Super. 533, 538-39 (App. Div. 1954); see In re Estate of Churik, 165 N.J.
Super. 1, 5 (App. Div. 1978), aff'd o.b., 78 N.J. 563 (1979). See also Pascale v.
Pascale, supra, 113 N.J. at 31 (holding that donee of inter vivos gift bears burden
of proof by clear and convincing evidence).
The court held The record before us discloses no evidence by which
Thomas could meet this burden. On the contrary, the record is overwhelmingly
supportive of the finding of undue influence. The combination of the confidential
relationship and the suspicious circumstances was more than sufficient to shift
the burden to Thomas. The absence of any evidence tending to negate the
presumption and the abundant evidence of self-dealing by Thomas support the
conclusion that the testator's will was overborne. The trial judge, having heard
and considered the evidence, appropriately found that the burden that had
shifted to Thomas was one that he was unable to carry. Affirmed.
KENNETH VERCAMMEN & ASSOCIATES, PC
ATTORNEY AT LAW
2053 Woodbridge Ave.
Edison, NJ 08817
(Phone) 732-572-0500
(Fax) 732-572-0030
TRIAL AND LITIGATION EXPERIENCE
In his private practice, he has devoted a substantial portion of his
professional time to the preparation and trial of litigated matters. He appears in
Courts throughout New Jersey several times each week on many personal injury
matters, Criminal and Municipal/traffic Court trials, Probate hearings, and
contested administrative law hearings.

Mr. Vercammen served as the Prosecutor for the Township of Cranbury,

Middlesex County and was involved in trials on a weekly basis. He also argued
all pre-trial motions and post-trial applications on behalf of the State of New
Jersey.
He has also served as a Special Acting Prosecutor in Woodbridge, Perth
Amboy, Hightstown, Carteret, East Brunswick, Jamesburg, South Brunswick,
South River and South Plainfield for conflict cases.
Since 1989, he has
personally handled hundreds of criminal and motor vehicle matters as a
Prosecutor and now as defense counsel and has had substantial success.
Previously, Mr. Vercammen was Public Defender for the Township of Edison
and Borough of Metuchen and a Designated Counsel for the Middlesex County
Public Defender's Office.
He represented
indigent individuals facing
consequences of magnitude. He was in Court trying cases and making motions
in difficult criminal and DWI matters. Every case he personally handled and
prepared.
His resume sets forth the numerous bar associations and activities which
demonstrate his commitment to the legal profession and providing quality
representation to clients.
Since 1985, his primary concentration has been on litigation matters. Mr.
Vercammen gained other legal experiences as the Confidential Law Clerk to the
Court of Appeals of Maryland (Supreme Court) with the Delaware County, PA
District Attorney Office handling Probable Cause Hearings, Middlesex County
Probation Department as a Probation Officer, and an Executive Assistant to
Scranton District Magistrate, Thomas Hart, in Scranton, PA.