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HomeMy WebLinkAbout01-5833 AMANDA LYNN NICOLE STATLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL Y ANIA v. 01- 5433 CIVIL ACTION -LAW ROBERT BISHOP PROYINS, Defendant IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plaintiff is Amanda Lynn Nicole Statler, an adult individual currently residing at 19 Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Robert Bishop Provins, an adult individual currently residing at 58 Mt. Rock Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the child, Logan Bishop Statler, who was born on May 17, 1998. The child was born out of wedlock. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: The child has exclusively lived with the Plaintiff since his birth on May 17, 1998. 4. The relationship of the Plaintiff to the child is that of mother. She is single and living separately. The Plaintiff currently resides with the following: Name Relationship Brian E. Deaven Boyfriend Briana Marie Lynn Deaven Daughter 5. The relationship of the Defendant to the child is that of Father. He is single and living separately. The Defendant currently resides with: Name Thomas Provins Relationship Father Ruth Provins Katie Provins Mother Sister 6. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in any other court. 8. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because: She is best able to provide a nurturing environment for her son. 9. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant her the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTS ON DEARDORFF WILLIAMS & OTTO By rL 'l\,Jl, ,~. Thomas J. Wil' s, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiffs Date: October 8, 2001 . . VERIFICATION The foregoing Complaint to Confirm Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content ofthe document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Or^a~~~~ Amanda Lynn Nicole Statler u ~ i ~ c1 ~ - .......I '81 - ....:r ~ ~ ..c. C V: <..J'., ~ ~ .....) ~. <::'. , ~ ~ Q5f'~'; Zi.', (/J -< ~ ~= (~.,~',: >c ~C:\ =< ::::> -) ~-.-t I .D I' '._':.-. "T, : ~ ~~ Cd -, (~ ~=--l 2;-~ n '-< AMANn<L_ ",COLUPA PL... '''' "'" CO""p OFeOMMON PLEAs 0' Plaintiff : CUMBERLAND COUNTy,PENNSYL VANIA NOli 2 72001 V. ROBERT BISHOP PROVINS, Defendant : NO. 2001-5833 CIVIL TERM : CIVIL ACTION - LA W : IN CUSTODY ORDER OF COVIq AND NOW, W, (" Ii. day of 1:;, c.u~L" ~ 2001, opo, """d,,,"oo of"" ."""'" ""fody Co""...oo ",port, it " ""'_ "'" ""'''d " follows: L Mo~~ """1 haw Prim"" ph,.."" ""tody of to""" .;,;,op Sta"~, born May 17,1998. 2. Father shall have periods of unsUpervised Partial custody two days per week from 5:30 p.m., when Mother shall drop the child at Father's residence, until 8:00 p.m. when Father shall return the child to Mother's residence. 3. Father shall notifY Mother in advance, when he receives his Work schedule, of the two days per Week that he intends to exercise his periods of Partial physical custody. 4. Neither Party shall pennit the child to have contact with the child's maternal grandparents. 5. The Parties shall return to a Conciliation Conference scheduled for December 19,2001 at 8:00 a.m. BY THE COURT, cc: Thomas 1. Williams, Esquire, counsel for Mother Gina Cames, certified legal intern, Family Law Clinic Teri Henning, Esquire, counsel for Father ~ J. ;1~ ~ L /2-).-0 ~ 'v'\N'v'fll'\SNN3d )J.N(lOG O>.N1\:\38'1'1f'\c) g \ :2 \~d CJ - 'J3G \ 0 ,\'2N i(;,;)' J. ',' ", :!.o "3:):UO-,:,1,'~r\'::.\ ;ejjJ),.iL ~\}jfjthl':!fi l!! NOV 2 7 200' AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYL VANIA V. ROBERT BISHOP PROVINS, Defendant : 2001-5833 CIVIL TERM : CIVIL ACTION - LAW PRIOR JUDGE: None : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPOIIT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the fol1owing report: 1. The pertinent infonnation conceming the Child who is the subject of this litigation is as fol1ows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Logan Bishop Statler May 17, 1998 Mother 2. A Conciliation Conference was held in this matter on November 21, 2001. The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Thomas J. Williams, Esquire. Father, Robert Bishop Provins, appeared with counsel, Gina Cames, certified legal intern from the Family Law Clinic, along with Teri Henning, Esquire. 3. The Parties agreed to entry of an Order in the fonn as attached. 11-;;.. 7-0/ Date Ja ueline M. Verney, Esquire Custody Conciliator i:'.iJ 1. h 2Dl12 ~ ~ AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYL VANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this .7_::<~J..day of ~ ?Y"7v ?.J 1 ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The prior Order of Court dated December 6, 200 I is hereby vacated and replaced with this Order. 2. The Mother, Amanda Lynn Nicole Statler, and the Father, Robert Bishop Provens, shall have shared legal custody of Logan Bishop Statler, born May 17, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. custody: Father shall have the following periods of unsupervised partial physical A. Every Wednesday from 5:00 p.m. to 8:00 p.m. and every Friday from 5:00 p.m. to 8:30 p.m. Father shall pick up the Child at daycare for these two weekly periods and return the child to Mother's residence. B. Alternating Saturdays from 9:00 a.m. to 5:00 p.m. 5. Neither party shall permit the Child to have contact with any member of Mother's family. 6. Father shall be responsible for all transportation. 7. Father shall provide dinner for the Child on Wednesday and Friday evenings and appropriate meals on Saturdays. 8. Father shall knock on Mother's door before entering her home. 9. Father shall keep Mother's unlisted telephone number confidential. 10. Father shall investigate and consider attending a parenting class. 11. 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, the terms of this Order shall control. BY THE COURT, J. cc: Thomas J. Williams, Esquire, counsel for Mother Elisabeth Rowley, certified legal intern, Family Law Clinic Thomas Place, Esquire, counsel for Father ~ {J'.lIia.rY\S ~\i-z..dne.~ ~ow\~ > ~ -fY);JJ o h:l tf -0 ;).. ~X5 Jr\N } Ii> t002 ~ AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLV ANIA V. : 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Logan Bishop Statler May 17, 1998 Mother 2. A Conciliation Conference was held in this matter on January 16, 200 I. The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Thomas J. Williams, Esquire. Father, Robert Bishop Provins, appeared with counsel, Elisabeth Rowley, certified legal intern from the Family Law Clinic, along with Tom Place, Esquire. 3. The parties agreed to an Order of Court at the initial conciliation conference which was entered by the Honorable J. Wesley Oler, Jr. and dated December 6, 2001. 4. The parties agreed to entry of a revised Order in the form as attached. /- 1(" -Oq Date 9h.L acq line M. Verney, Esquire Custody Conciliator OF 02 JM/24 PI~ 2: 24 CUM8E.hU\ND COUNIY PENNSYLVANIA , GARY L. & THERESA M. STATLER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs v. CIVIL ACTION - LAW AMANDA LYNN NICOLE STATLER, Defendant NO. 02-0826 CIVIL TERM AMANDA LYNN NICOLE STATLER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. CIVIL ACTION - LAW / ROBERT BISHOP PROVINS, Defendant NO. 01-5833 CIVIL TERM IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFFS' COMPLAINT IN CUSTODY AND PETITION FOR SPECIAL RELIEF tl ORDER OF COURT AND NOW, this I~~;;Y of March, 2002, after careful consideration of Defendant's "Preliminary Objections to Plaintiffs' Complaint in Custody and Petition for Special Relief," of Plaintiffs' "Complaint in Custody," and of Plaintiffs' "Petition for Special Relief," it is hereby ordered and directed as follows: 1. With respect to Defendant's first objection, that the complaint in custody and petition for special relief should be dismissed for failure to conform to court rules and for the inclusion of scandalous and impertinent matter, and it appearing that the petition for special relief refers to two children, Logan Bishop Statler and Brianna Marie Lynn Deaven, whereas the complaint in custody refers only to one child, Logan Bishop Statler, the objection is granted to the extent that any references to Brianna Marie Lynn Deaven in the petition for special relief are stricken. The objection is otherwise denied. 2. With respect to Defendant's second objection, that the complaint in custody and petition for special relief should be dismissed as improper because of the pendency of ~ VINVA1ASNN3d )J.Nno~) (l'!'r;Li]fiWn8 ""',. " II:! ....'o '? 1.,-'.. ../\",00 '..., ,.',"_ '" ""'120 ':.1 Cd}' -:.,,,-<. JJ an existing action, and it appearing that a custody action concerning Logan Bishop Statler is pending in this court at No. 01-5833 Civil Term, the objection is granted to the extent that the current custody action shall be consolidated with the action at No. 01-5833 Civil Term under that docket number. Plaintiffs in the current action shall serve upon Robert Bishop Provins, a named party in the action at No. 01-5833 Civil Term, a copy of all prior pleadings filed in the current action. The custody complaint and petition for special relief filed at No. 02-0826 Civil Term shall be docketed at No. 01-5833 Civil Term and all future filings in the current action shall be made at No. 01-5833 Civil Term. The objection is otherwise denied. 3. With respect to Defendant's third objection, that the complaint in custody and petition for special relief should be dismissed for failure to join a necessary party, Robert Bishop Provins, the father of Logan Bishop Statler, the objection is deemed moot by virtue of the consolidation of the current action with the action at No. 01-5833 Civil Term, in which Robert Bishop Provins is a named party. BY THE COURT, ~L. Statler Theresa M. Statler 105 Farm Road Newville, PA 17241 Pro Se Plaintiffs ~s J. Williams, Esq. Ten East High Street Carlisle, P A 17013-3093 Attorney for Defendant Amanda Lynn Nicole Statler 7 L r -fI~ 03- J.5 -():;). ~ 'X5 . ~mas Place, Esq. 45 North Pitt Street Carlisle, P A 17013 Attorney for Defendant Robert Bishop Provins ~ueline M. Verney, Esq. Custody Conciliator AMANDA LYNN NICOLE STATLER, Plaintiffi'Respondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY ROBERT BISHOP PROVINS, DefendantJPetitioner NO. 01 - 5833 CIVIL TERM OBJECTIONS TO SUBPOENA DefendantJPetitioner, Robert Bishop Provins, by his attorney, the Family Law Clinic, pursuant to Rules 1915.5 (c) and 1930.5, objects to the proposed subpoena that is attached to these objections for the following reasons: 1. The proposed Subpoena to Produce Documents or Things For Discovery Pursuant to Rule 4009.22 that is attached to these objections was filed under Custody Docket No. 01-5833. 2. Pursuant to Rule 1915.5(c), which specifically addresses the question of discovery in actions for custody, partial custody and visitation of minor children, there shall be no discovery unless authorized by special order of court. 3. Furthermore, pursuant to Rule 1930.5 Discovery in Domestic Relations Matters, there shall be no discovery in a simple support, custody or Protection from Abuse proceeding unless authorized by order of court. 4. The Plaintiff/Respondent in this matter has not obtained such special order of court, nor asserted any basis for such a special order of court. WHEREFORE, the Defendant/Petitioner requests that the Subpoena to Produce Documents or Things For Discovery Pursuant to Rule 4009.22 be quashed. Date: 1ft::>! f);L lisabeth L. ley Certified Legal Int ~0J;L THO S ROBER . RAINS LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 MT .L 6] R MEDICAL LEGAL REPRODUCTIONS. INC Main OfTu;e 4940 Disston Street Philadelphia, Pa. 19135 Phone: (215) 335-3212 Fax: (215) 338-2980 E-mail Address:legal@medleg.com Jefferson Bldg., Suite 926 1015 Chestnut Street Philadelphia, Pa. 19107 Mar 01, 2002 TERRI HENNING, ESQUIRE 45 N PITT ST CARLISLE PA 17013 Re: ROBERT BISHOP PROVINS Ca~tion: STATLER v. PROVINS Our Fl1e #: M284413 Dear Counselor: Enclosed please find a copy of a Notice of Intent to Serve Subpoena, together with the related Subpoena(s) for documents as they apply to the above captioned matter. If your office desires to order a copy of the requested information, please complete the order card enclosed. If you have any questions, or we can be of any further service, please do not hesitate to contact our office. Very truly yours, Jacqueline Ciarrochhi MEDICAL LEGAL REPRODUCTIONS, INC. (215) 335-3212 CMR/bc enclosures RECEIVED MAR - 6 2802 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATLER Vs. PROVINS No. 2001 5833 TO: TERRI HENNING NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PLAINTIFF intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 03/01/02 THOMAS J WILLIAMS, ESQUIRE MARTSON DEARDORFF TEN EAST HIGH ST CARLISLE, PA 17013 ATTORNEY FOR PLAINTIFF INQUIRIBS SHOULD BE ADDRBSSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Jacqueline Ciarrocchi Enc(s): Copy ofsubpoena(s) Counsel return card File #: M284413 ~TH OF pFllNSYLVANIA COONl'Y OF aJMBERIAND STATLER Va. Fi Ie No. ?001 'iR33 PROVINS TO: SUBPOENA TO PRODUCE DCX:l.t-ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 GIANT FOOD STORES, 255 S SPRING GARDEN ST, CARLISLE PA 17013 nT'J'l'l. PF.R!':{)1I'll\mT. nF.PAR'l'MF.NT (Name of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunentl'l or things: SEE ATTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(A~s1940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h, this subpoena, together with the certificate' of carc:>1iance, to the party making thi,. request at the address listed above. You have the right to seek in advance the reasonablE cost of preparing the copies or producing the things sought. I f you fai I to produce the docunents or things required by this subpoena within t..,enty (20) days after its serv~ce. the party serving thh !;ubpoena may seek a court orde.' ~elling you to carply with it. TH I S SUBPOENA WAS NA/'E : ADDRESS : ISSUED AT THE REQUEST OF THE FOLLO'/ING PERSON: T~{)Mn!': .7 WTT.T,IAMS, ESQ TELEPH:lNE: . SUPREI'E COURT I D # ATTORNEY FOR: ~Y5ON DEARDORFF CARLISLE, PA 17013 215-335-3212 PLAINTIFF BY THE CCXJRT: M284413-01 Prothonotary/Clerk, Civi 1 Division DATE: 03/22/02 . S,ea I of the Court Deputy (Eff. 1/97) ADDENDUM TO SUBPOENA STATLER Vs. No. 2001 5833 PROVINS CUSTODIAN OF RECORDS FOR: GIANT FOOD STORES ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS REVIEWS, .ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS AND PRE-EMPLOYMENT PHYSICALS,' WORKMEN'S COMPENSATION CLAIMS MADE, ANY W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO: NAME: ROBERT BISHOP PROVINS ADDRESS: ~2 MOUNT ROCK RD NEWVILLE PA CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS A V AlLABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed X-RAYS Date Author~zed s~gnature for GIANT FOOD STORES CUMBERLAND M284413-01 *** SIGN AND RETURN THIS PAGE *** AMANDA LYNN NICOLE STATLER, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN CUSTODY ROBERT BISHOP PROVINS, DefendantJPetitioner NO. 01 - 5833 CIVIL TERM CERTIFICATE OF SERVICE I, Elisabeth L. Rowley, hereby certifY that on this 15th day of March 2002, I am serving a true and correct copy ofDefendantJPetitioner's Objections to Subpoena on Thomas 1. Williams, Esquire, at Martson Deardorff Williams & Otto, 10 East High Street, Carlisle, P A 17013 and on Jacqueline Ciarrochhi, at Medical Legal Productions, Inc., 4940 Disston Street, Philadelphia, PA 19135 by first class U.S. mail. 3//5/0:), Date F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 (") = CJ C '" ",1 s,~ --..: ""1J D.: ~."" rn r :0 :~~ -, iJ ~ _."'-1 Z C: ~ en ~') :? ~~) ~ C) "0 i ~ c:; _1:\. l Fl~ .>:,.:' C) w ~ C. ~.:~ :::. ::) ~~; -'-1 -<. (.J -< ",:"",j;",_'JUMIi~jl(a{"kf.tic,;~~:};;lbk:;;-:; i"T >- C" >- C',; c:::; l~-; ,.. /- c... :J - C) ". 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AMANDA LYNN NICOLE STATLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW ROBERT BISHOP PROVlNS, Defendant NO. 01-5833 CIVIL TERM ORDER OF COURT AND NOW, this 27th day of March, 2002, upon consideration of Defendant's Objections to Subpoenas, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Thomas J. Williams, Esq. 10 East High Street Carlisle, PA 17013 Attorney for Plaintiff '~ ~ 4.0J.0:l-> ~ \ii~J\//\1^Sr,lN3d I 'f !n~'-'.I n\'.""'. '-'.'''''1'''' lli \J !l_J.. '. :.:,' <,_.;:;{~ Iv ~I I "I ~-1"""'70 t':: >.:u (5{, a~~'i (.. ~: ....':1 ,... ~.J . Elisabeth L. Bowley Certified Legal Intern Thomas M. Place, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Supervising Attorneys Attorneys for Defendant :rc APft^~ 2002 AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF PlaintiCC : CUMBERLAND COUNTY , PENNSYLVANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, DeCendant : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER, : IN THE COURT OF COMMON PLEAS OF PlaintiCCs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW DeCendant : IN CUSTODY ORDER OF COURT AND NOW, this I (,., ttuay of ~ ~-.J ~ I ,2002, upon consideration of the attached Custody Conciliation R' port, It IS ordered and directed as follows: I. The prior Order of Court dated January 23, 2002 is hereby vacated. 2. The Mother, Amanda Lynn Nicole Statler, and the Father, Robert Bishop Provens, shall have shared legal custody of Logan Bishop Statler, born May 17, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. custody: Father shall have the following periods of unsupervised partial physical A. Every Wednesday and Thursday from 5:00 p.m. to 8:00 p.m. Father shall pick up the Child at daycare for these two weekly periods and return the child to Mother's residence. B. Beginning April 14, 2002, alternating Sundays from 9:00 a.m. to 5:00 p.m. 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. ItINV^lASNN3d AlNnC'fl GN~'lt!38V'jno ~z :01 WJ I. IlJdV ZO Al:J\I10NOH1Udd 3Hl 30 381330-03113 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. 7. Father shall provide dinner for the Child on Wednesday and Thursday evenings and appropriate meals on Sundays. 8. Father shall knock on Mother's door before entering her home. 9. Father shall keep Mother's unlisted telephone number confidential. 10. Father shall investigate and consider attending a parenting class. 11. Father shall be entitled to one phone call with the child weekly. 12. Grandparents shall have supervised visitation with the child at the Carlisle YWCA on the third Saturday of every month for two hours. In the event the YWCA cannot accommodate this time, the parties shall set a mutually agreeable day and time to allow for a two hour supervised visit once a month. 13. Transportation of the child for Grandparent's visit shall be the responsibility of the Mother. 14. 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, the terms of this Order shall control. Another Conciliation Conference is scheduled for July 3, 2002 at 8:30 a.m. BY THE COURT, J. cc~omas J. Williams, Esquire, counsel for Mother ~isabeth Rowley, certified legal intern, Family Law Clinic :~y Johnston Walsh, Esquire, counsel for Father 7thony T. McBeth, Esquire, counsel for Grandparents t<ryi= ~ D4'I'J-D~ ~S ApI? maOt AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, DeCendant : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER : IN THE COURT OF COMMON PLEAS OF PlaintiCCs : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2002-0826 CIVI TERM AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: J. Westey Oter, Jr. 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 Logan Bishop Statler May 17,1998 Mother 2. A Conciliation Conference was held in this matter on April 1 0, 2002. The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Thomas J. Williams, Esquire. Father, Robert Bishop Provins, appeared with counsel, Elisabeth Rowley, certified legal intern from the Family Law Clinic, along with Lucy Johnston Walsh, Esquire. The maternal Grandparents, Gary 1. and Theresa M. Statler appeared with counsel, Anthony T. McBeth, Esquire. 3. A prior Order of Court, entered by the Honorable 1. Wesley Oler, Jr. was dated January 23, 2002. That Order provided for shared legal custody and for Mother to have primary physical custody with Father having periods of partial physical custody. Subsequent to that Order, Grandparents filed a custody action. The Honorable J. Wesley Oler, Jr. entered an Order dated March 14,2002. That Order disposed of Preliminary Objections filed by Mother to the custody complaint filed by the Grandparents. The Court ordered the consolidation of the Grandparents custody complaint with the prior custody action filed by Mother against Father. 4. The following matters were before the Conciliator for consideration: A. Mother's Petition for Contempt against Father. This Petition was withdrawn by Mother at the Conciliation Conference. In addition, however, the parents agreed to amend the Order of Court, dated January 23,2002 to accommodate Father's changed work schedule. B. Grandparents custody complaint and amended custody complaint, which included Brianna Marie Lynn Statler. Grandparents withdrew their amended custody complaint regarding Brianna Marie Lynn Statler at the Conciliation Conference. 5. The parties agreed to entry of an Order in the form as attached. L!_I;;" -0"2- Date ~~h Custody Conciliator . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-05842 NEWVILLE BOROUGH, Plaintiff BOBBY KENDALL, Defendant CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please note Plaintiff s receipt of full payment by Defendant, including interest and costs. Please cause the record of this case to be marked as discontinued and the judgment obligation satisfied. WEIGLE & ASSOCIATES, P.C. By: --?- r rz.-.,~b ~ Richard 1. Webber, Jr., Esquire Attorney for Plaintiff Attorney l.D. #49634 126 East King Street Shippensburg, P A 17257 Telephone (717) 532-7388 Dated: '1'(ldo').. WEIGLE & ASSOCIATES, Re. _ ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 '. 8 <::> 0 N "'q :s:: """ ---i "Uo:; " :}ii~ mrn ;;0 2:1:' ZC: ry'll cn<,: -.J '.::'9 ~t:_: \~::(J """ "7:"." ~c: ~. ;""):!J - ~-,.() zc~ - 25r1'1 j; -- - c :z -:n ,~ ~ S:J ()J -< AMANDA LYNN NICOLE STATLER, Plaintifti'Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY ROBERT BISHOP PROVINS, DefendantJPetitioner NO. 01 - 5833 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE AND NOW, comes the DefendantJPetitioner Robert Bishop Provins, by and through his attorneys, the Family Law Clinic, and files this Petition to Make the Rule, issued on March 27, 2002, Absolute and states as follows: 1. On March I, 2002, PlaintiffiRespondent Amanda Lynn Nicole Statler filed a Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22, which was then served on Robert Bishop Provins and the Giant Food Stores. 2. On March 15, 2002, Robert Bishop Provins filed Objections to Subpoena pursuant to Rule 1915.5(c), which specifically addresses the question of discovery in actions for custody, partial custody, and visitation of a minor children, and states that there shall be no discovery unless authorized by special order of court, and pursuant to Rule 1930.5 Discovery in Domestic Relations Matters, which states that there shall be no discovery in a simple support, custody or Protection from Abuse proceeding unless authorized by order of court. 3. On March 27,2002, the Honorable J. Wesley Oler, Jr. issued a Rule upon Amanda Lynn Nicole Statler directing her to show cause within twenty (20) days of service why the Subpoena should not be quashed. 4. More than twenty (20) days have passed and Respondent Amanda Lynn Nicole Statler has filed no response to the Rule to Show Cause. WHEREFORE, Robert Bishop Provins requests that the Court make the rule absolute and grant the Objections to Subpoena, directing that the Subpoena to Produce Documents or Things for Discovery Pursuant to Rule 4009.22 be quashed. Respectfully submitted, Date~ isabeth 1. Ro Certified Legal Intern ~~~tJ~ ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 AMANDA LYNN NICOLE STATLER, Plaintiffi'Respondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW : IN CUSTODY ROBERT BISHOP PROVINS, DefendantJPetitioner NO. 01 - 5833 CIVIL TERM CERTIFICATE OF SERVICE I, Elisabeth L. Rowley, hereby certifY that on this 22nd day of April 2002, I am serving a true and correct copy of Petition to Make the Rule Absolute on Thomas J. Williams, Esquire, at Martson Deardorff Williams & Otto, 10 East High Street, Carlisle, PA 17013, Anthony T. McBeth, Esquire, at 407 North Front Street, Cameron Mansion, Harrisburg, PA 17101, and Jacqueline Ciarrochhi, at Medical Legal Productions, Inc., 4940 Disston Street, Philadelphia, P A 19135 by first class U.S. mail. <f/j()/OJ- Date FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 >- ,~ t.uC:? f~;/i~~' (;),"- cj'/ LL{i.), C:.',' ~: L~_ o ...::- ~\. ..::r ""-' i':: > -" (~ff :"0') --:J ," >- .:.'lj) J~ /~JlE -, :S <.> C:.: <:\J C\.J Q:: Q. ~ <'\J C') APR 2 3 2002..) AMANDA LYNN NICOLE STATLER, PlaintifilRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION-LAW : IN CUSTODY ROBERT BISHOP PROVINS, DefendantJPetitioner NO. 01 - 5833 CIVIL TERM ORDER OF COURT AND NOW this 'J~~ r ~ day of April 2002, a RuIe to Show Cause having been issued and no response having been filed, it is hereby Ordered that DefendantJPetitioner's Objections to Subpoena is granted. The Subpoena to Produce Docwnents or Things for Discovery Pursuant to Rule 4009.22 is hereby quashed. J. t L O~;~~O:l R)\s to: ~..h 50..\e. th L. Kow \~ ~. 1JilliD.rrl5 o.H:~. f"\ Co Be th . Jo..c.~ Ue. \i 1'\ e Cia. r roet JJ.Nn,~~"V~.y.,StvNJd " '.1, ;"7L/1911170 0/ ://IIV 7C(JdV20 AI:JVjO"", ,'. <,\;-'i/.i'-':~j:J .) 'I ::J\i:':l"/n_"~rh;-J: ::J. ,::fQ ". l.,,://,'::./ ;IIii.'IJ,~~:(lll!!,!,ili<l...! }j;.i:.'t'h.,G, .,.._ ~Jin\" ..', ~._, .m.'.. . AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 scheduled hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE ALA WYER 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 2 Uberty Avenue Carlisle, P A 17013 (717) 249-3166 AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION - LAW ROBERT BISHOP PROVINS, Defendant : NO. 2001-5833 CIVIL TERM : IN CUSTODY GARY L. STATLER and THERESAM. STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER,: ROBERT PROVINS and : IN CUSTODY BRIAN DEA VEN, Defendants GARY L. AND THERESA M. STATLER'S PETITION TO MODIFY EXISTING ORDER 1. On April 1 0, 2002, the parties held a conciliation conference before Jacqueline M. Verney, Esquire, the conciliator appointed for the captioned consolidated case. 2. As a result of that conciliation. an order of this Court (specifically, by J. Wesley Oler, Jr., Judge) was issued on April 16, 2002. A copy of that order is attached hereto, marked Exlubit <<A" and incorporated herein by reference. The order provides for Gary L. and Theresa M. Statler to have supervised visitation with their grandson. Logan Bishop Statler at the Carlisle YWCA. 3. At the conciliation. the parties also discussed and agreed to Gary and Theresa Statler having telephone contact with Logan Statler (their grandson), on at least a weekly basis. But, no such provision was placed in the April 16 order. 4. On May 10, 2002, the undersigned learned from Jan Booty of the Carlisle YWCA, that that facility could not and would not arrange for such supervised visitations as contemplated by the April 16,2002 order. . 5. The reason that the undersigned was given for the refusal to participate in such supervised visitation is that, inasmuch as Gary L. Statler is charged with certain sexual offenses (not convicted; merely charged), the Carlisle YWCA believes that assisting him with supervised visitation is "contrary to the mission of the Carlisle YWCA" in that the facility also serves as a Rape Crisis Center, and representatives of the Carlisle YWCA believe that assisting Mr. Statler in such circumstances could costs that facility some of its funding. 6. Because of other difficuhies that Gary and Theresa Statler had experienced in setting up the supervised visitation with the Carlisle YWCA, they had also checked with the Harrisburg YWCA. Mr. and Mrs. Statler fully disclosed the fact that Gary Statler is charged with the offenses descn"bed in the previous paragraph; according to personnel at the Harrisburg YWCA, that fact presents no impediment to the Harrisburg YWCA arranging and monitoring the supervised visitation. 7. As part of their contact with the Harrisburg YWCA, Gary and Theresa Statler learned that, when a fiunily is involved with supervised visitation, there are separate parking facilities and separate entrances for the parties involved in the visitation, that the facility will not charge any party for the supervised visitation and that personnel of that facility will voluntarily provide summary statements to the parties' counsel describing the events of and quality ofthe visit. 8. Defendant Amanda Lynn Nicole Statler, through her counsel, has been informed of all of these facts (including the absence of telephone provisions in the April 16 order) and arbitrarily refuses to agree to either supervised visitation at the Harrisburg YWCA or any telephone contact. 2 9. Through the telephone conversation with Jan Booty as descnDed above, the undersigned also learned that, apart from the Carlisle YWCA, the only other facilities available in the South Central Pennsylvania area for supervised visitation as contemplated by the parties are the Harrisburg YWCA, Inner Works in Harrisburg and the Keystone Family Services Center, also in Harrisburg. 10. As a resuh of the difficulties and intransigence descn"bed above, Gary and Theresa Statler have had no visitation of any kind and no telephone contact of any kind with their grandson, as contemplated by the April 16, 2002 order; under these conditions, Gary and Theresa Statler believe and therefore aver that it is necessary for the Court to modifY its April 16 order to provide for supervised visitations at the Harrisburg YWCA and to provide for telephone contact on at least a weekly basis, as the parties agreed at the April 10, 2002 conciliation. WHEREFORE, Gary and Theresa Statler request this Honorable Court to modifY its order to provide for supervised visitation at the Harrisburg YWCA, to allow telephone contact with there grandson, Logan Statler on at least a weekly basis, and to provide any other relief this Court deems appropriate. 3 AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : NO. 2001-5833 CML TERM : IN CUSTODY GARYL. STATLER and THERESAM. STATLER, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : ROBERT PROVINS and ' : IN CUSTODY BRIAN DEA VEN, Defendants CERTIFICATE OF SERVICE I, Anthony T. McBeth, Esquire, hereby certify that I have served to persons listed below with the attached docwnent, by first class mail, postage pre-paid, on the date indicated below: ~13'21JOZ-- Date Thomas J. Williams, Esquire Martson, Deardorff, Williams & Otto Ten East High Street Carlisle, PA 17013 (Attorneys for Amanda Statler) Elisabeth L. Rowley, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (Attorneys for Robert Bishop ,.," A~R ~2002 AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this JID11l day of ,2002, upon consideration of the attached Custody Concilia ion Report, it is ordered and directed as follows: 1. The prior Order of Court dated January 23, 2002 is hereby vacated. 2. The Mother, Amanda Lynn Nicole Statler, and the Father, Robert Bishop Provens, shall have shared legal custody of Logan Bishop Statler, bOlll May 17, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. custody: Father shall have the following periods of unsupervised partial physical A. Every Wednesday and Thursday from 5:00 p.m. to 8:00 p.m. Father shall pick up the Child at daycare for these two weekly periods and return the child to Mother's residence. . B. Beginning April 14, 2002, alternating Sundays from 9:00 a.m. to 5:00 p.m. 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. EXHIBIT "A" 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. 7. Father shall provide dinner for the Child on Wednesday and Thursday evenings and appropriate meals on Sundays. 8. Father shall knock on Mother's door before entering her home. 9. Father shall keep Mother's unlisted telephone number confidential. 10. Father shall investigate and consider attending a parenting class. 11. Father shall be entitled to one phone call with the child weekly. 12. Grandparents shall have supervised visitation with the child at the Carlisle YWCA on the third Saturday of every month for two hours. In the event the YWCA cannot accommodate this time, the parties shall set a mutually agreeable day and time to allow for a two hour supervised visit once a month. 13. Transportation of the child for Grandparent's visit shall be the responsibility of the Mother. 14. 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, the terms of this Order shall control. Another Conciliation Conference is scheduled for July 3, 2002 at 8:30 a.m. BY THE COURT, J. cc: Thomas J. Williams, Esquire, counsel for Mother Elisabeth Rowley, certified legal intern, Family Law Clinic Lucy Johnston Walsh, Esquire, counsel for Father Anthony T. McBeth, Esquire, counsel for Grandparents TRUE coPY FROM RECORD rn T.estimony whercof,lhere unto set my hand and th seal of said our at arlisle, Pa. This . .....1.7..... d f..... p.At., - OJ. p; tWm;;;,v::11ft. APR k2002 AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2002-0826 CIVI TERM AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COl)NTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation concerning the Child who is the subject of this " litigation is as follows: -';' NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF fLogan Bishop Statler May 17, 1998 Mother 2. A Conciliation Conference was held in this matter on April 10, 2002. The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Thomas J. Williams, Esquire. Father, Robert Bishop Provins, appeared with counsel, Elisabeth Rowley, certified legal intern from the Family Law Clinic, along with Lucy Johnston Walsh, Esquire. The maternal Grandparents, Gary L. and Theresa M. Statler appeared with counsel, Anthony T. McBeth, Esquire. 3. A prior Order of Court, entered by the Honorable J. Wesley Oler, Jr. was dated January 23, 2002. That Order provided for shared legal custody and for Mother to have primary physical custody with Father having periods of partial physical custody. Subsequent to that Order, Grandparents filed a custody action. The Honorable J. Wesley Oler, Jr. entered an Order dated March 14,2002. That Order disposed of Preliminary Objections filed by Mother to the custody complaint filed by the Grandparents. The Court ordered the consolidation of the Grandparents custody complaint with the prior custody action filed by Mother against Father. 4. The following matters were before the Conciliator for consideration: A. Mother's Petition for Contempt against Father. This Petition was withdrawn by Mother at the Conciliation Conference. In addition, however, the parents agreed to amend the Order of Court, dated January 23,2002 to accommodate Father's changed work schedule. B. Grandparents custody complaint and amended custody complaint, which included Brianna Marie Lynn Statler. Grandparents withdrew their amended custody complaint regarding Brianna Marit: Lynn Statler at the Conciliation Conference. 5. The parties agreed to entry of an Order in the fOffil as attached. 1-/_ /~ -0"2- Date que ne M. Verney, Esquire Custody Conciliator " ~ . VERIFICATION We, Gary L. Statler and Theresa M. Statler, Plaintiffs in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of our knowledge, information and belief. We so state subject to the penalties of 18 Pa. C. S. ~4904 (relating to unsworn falsification to authorities). MAY 13, 2002 Date MAY 13. 2002 Date >- ~ Y~IC; i,.J " en c r-; ?:; J':"~ .:::=:J ._ -\::-:,. !(~:~~ -,P .,-,- "",0) ,~': ~ ~~ "nw ~:~>J 0.... ~ --, o .r_.. c.. "" "..) ~ '," :.... ('..J (::. ...):- ct ~~ 8 a ~ ~~L 1\ i1-0~ PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA LYNN NICOLE STATLER V. 01-5833 CIVIL ACTION LAW ROBERT BISHOP PROVINS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on . Tuesday, June 25, 2002 at 11:30 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 present 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 aU existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. VernQ'. Esq. ~ Custody Conciliator 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~ ~ ~~~ {(?-At:'-,> I-~ &'" ~ b 2~ ~t4 ~O'h~p ~.?~ ~ ~~ ~ /p eo/]c='Y - . ViN'v'^lASNN3d A.L\1nOO ON'7:1r:;8V~n:J LU:l'j ~Id iIGAV~jZ0 AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. 2001-5833 CIVIL TERM ~ : IN CUSTODY ROBERT BISHOP PROVINS, Defendant GARYL. STATLER and THERESAM. STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : ROBERT PROVINS and : IN CUSTODY BRIAN DEAVEN, Defendants STIPULATION OF THE PARTIES REGARDING MODIFICATION OF APRIL 16.2002 ORDER WHEREAS, because of changed circumstances, the Parties desire to amend the tenns of the Order entered by this Court in the captioned action on April 16, 2002, the Parties hereby stipulate as follows: 1.) all tenns of the April 16, 2002 Order remain in effect, except for the changes described in the following paragraphs; 2. paragraph 12 of the Apri116, 2002 Order is amended to provide that the grandparents, Gary L. and Theresa M. Statler shall have supervised visitation with Logan Bishop Statler on the second Tuesday of each month from 6:00 P.M. until 8:00 P.M. at the Harrisburg, Pennsylvania YWCA; 3.) the grandparents, Gary L. and Theresa M. Statler are permitted to have telephone contact .. . with Logan Bishop Statler when his futher, Robert Bishop Provins, is exercising periods of partial custody on Wednesday evenings, Thursday evenings and Sundays. .A'~~,~,. Amanda Lynn Statler ~~ Robert Bishop Provins n!.~~~ ... . . ~ (") a 0 c.:: f'J -'1 ;::: '- l:1G.' C rnrn :.~ 2:]:_ .,~ ~. N <<":"- ~1> (Ji !;:'c:" " >- l..'....:> -...... c <21 5> s::; :.oj <:. :'\,) =<! .-../ 1/ " :';. .. 2002 JUN 2 6 2002 i AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYL VANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 26th day of June, 2002, the Conciliator being notified that the parties have reached an agreement by stipulation, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 1h. ~ (") = C) C I'V -n s- o "1J en c:: -'-r"~ rn :+~ "~ -7 .r._ ~ -- N ::-~ ,"' \,~ CI) :;':'- .-J , , -< _-:: ';~ ~;;: L. .'-" ~ >- (~-.... C) Z ~~. :> :...D c -'j ."n ::~~ :;::i :j :.J1 J-J -, .~- -< j' ...J ..... AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. 2001-5833 CIVIL TERM ~ : IN CUSTODY - ROBERT BISHOP PROVINS, Defendant GARYL. STATLER and THERESAM. STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : ROBERT PROVINS and : IN CUSTODY BRIAN DEAVEN, Defendants STIPULATION OF THE PARTIES REGARDING MODIFICATION OF APRIl. 16.2002 ORDER WHEREAS, because of changed circumstances, the Parties desire to amend the tenns ofthe Order entered by this Court in the captioned action on April 16, 2002, the Parties hereby stipulate as follows: 1.) all tenns of the April 16, 2002 Order remain in effect, except for the changes described in the following paragraphs; 2. paragraph 12 of the Apri116, 2002 Order is amended to provide that the grandparents, Gary L. and Theresa M. Statler shaI1 have supervised visitation with Logan Bishop Statler on the second Tuesday of each month from 6:00 P.M. until 8:00 P.M. at the Harrisburg, Pennsylvania YWCA; 3.) the grandparents, Gary L. and Theresa M. Statler are permitted to have telephone contact ;.. with Logan Bishop Statler when his futher, Robert Bishop Provins, is exercising periods of partial custody on Wednesday evenings, Thursday evenings and Sundays. .A"'~~,~- Amanda Lynn Statler n!.~!:w..~~ ~~ Robert Bishop Provins (") c.:: <:- -or.. (1) ff7 %j1; (n .,. -~.. r;: 1~~~' "$ zC:, 5>() c:: 2:' =<! :...> :'\,) --../ f'" ":,:' "" a f'V c.... C -- -- o -q '-.1 - r' i,:::,::: .': ~!J N (;1 =2 ~ C) : -',:j Kj~~a .::::/ ..,...... :.0 -< 2002 -' .- , ~ J~ 2002 AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS or" - · Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; NO. 2001-5833 CIVIL TERM ~ : IN CUSTODY ROBERT BISHOP PROVINS, Defendant GARYL. STATLER and THERESA M. STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NlCOLE STATLER,: ROBERT PROVINS and : IN CUSTODY BRIAN DEAVEN, Defendants ORDER AND NOW, this r:,tl. dayof~~ Co. , 2002, the attached Stipulation of the Parties is hereby adopted as an Order of Court. To the extent that this Order adds provisions or changes provisions from the previous Order in this case entered April 16, 2002, this Order shall control. BY THE COURT: ~& L.'1-I.O~.fft ~~ t.O : 1 ( 1'1 "lv. -1.J',I\ia.~ U fY\ Co 'Berb BrjotJ R. Ko.steR "',." \fINV,liIASNN3d r Li\fr)~" '",." .~~"'~O /\.1' I r } I ;~'\.'~ir <'~1~-,I~....rfnl'l I -"". \,' -'---'---'._,:. f! L Z :2 !Id I - lnr 20 _i'J ,.I,J AMANDA LYNN NICOLE STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO, 2001.5833 CIVIL TERM ROBERT BISHOP PROVINS : IN CUSTODY Defendant GARYL. STATLER and THERESA M, STATLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, : NO. 2002 - 0826 CIVIL TERM AMANDA LYNN NICOLE STATLER, ROBERT BISHOP PROVINS, and BRIAN DEA YEN, : IN CUSTODY Defendants PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, Robert Bishop Provins, by and through his counsel, Jane Adams, Esquire, and petitions the Court as follows: I. Robert Bishop Provins, (hereinafter referred to as "Falther") is an adult individual currently residing at 12 Mount Rock Road, Newville, Pa. 17241. 2. Amanda Lynn Deaven, formerly known as Amanda Lynn Nichole Statler, (hereinafter referred to as "Mother"), is currently residing at 312 Pine Road, Mount Holly Springs, Pennsylvania, 17065. 3. The parties are the natural parents of one child, namely, Logan Bishop Statler, (hereinafter referred to as "Child") born May 17, 1998. 4. A paternity test was previously performed which showed Robert Bishop Provins to be the natural father of the child. 5. Logan Bishop Statler is also known as Logan Bishop Deaven, due to Mother filing a sworn affidavit with Vital Statistics to change the child's name and the name of the father listed on the birth certificate. Natural father did not consent to the charlge in the birth certificate. 6. The parties are subject to Court Orders which are hereinafter attached as "Exhibit A". 7. The circumstances regarding the parties have changed and the current custody order is not currently appropriate for the parties. 8, Mother has repeatedly denied Father his periods of custody with the child. 9. Father is requesting an order which contains more sp'~cific provisions regarding holidays, transportation, and other issues regarding the child. 10. It is believed and averred that the best interest and permanent welfare of the child will be promoted by changes proposed in this custody petition. WHEREFORE, Plaintiff requests the court to set a conciliation date to examine issues regarding custody of the child. Respectfully submitted, Date: 75/71:{ (a5 J e Adams, Esquire I . No. 79465 4 South Pitt Street Carlisle, Pa.. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER ROBERT BISHOP PROVINS J~ 2002 AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS or" .. I Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. 2001-5833 CIVIL TERM V'" : IN CUSTODY ROBERT BISHOP PROVINS, Defendant GARYL. STATLER and THERESA M. STATLER, Plaintiff : IN THE COURT OF' COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER,: ROBERT PROVINS and : IN CUSTODY BRIAN DEAVEN, Defendants ORDER AND NOW, this r:,il. dayof~Wt c.. , 2002, the attached Stipulation of the Parties is hereby adopted as an Order of Court. To the extent that this Order adds provisions or changes provisions from the previous Order in this case entered April 16, 2002, this Order shall control. BY THE COURT: ~o:&L Lrt+o:t~RK~ t.o: I ( I'l illY. ""W'.I\ia.h\S U p\C.Be\-h B('~otJ R. Ko.s-l-eR tft AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. 2001-5833 CIVIL TERM ~ : IN CUSTODY - ROBERT BISHOP PROVINS, Defendant GARYL. STATLER and THERESAM. STATLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER,: ROBERT PROVINS and : IN CUSTODY BRIAN DEA YEN, Defendants STIPULATION OF THE PARTIES REGARDING MODIFICATION OF APRIL 16.2002 ORDER WHEREAS, because of changed circumstances, the Parties desire to amend the terms of the Order entered by this Court in the captioned action on April 16, 2002, the Parties hereby stipulate as follows: 1.) all terms of the April 16, 2002 Order remain in effect, except for the changes described in the following paragraphs; 2. paragraph 12 of the April 16, 2002 Order is amended to provide that the grandparents, Gary L. and Theresa M. Statler shall have supervised visitation with Logan Bishop Statler on the second Tuesday of each month from 6:00 P.M. until 8:00 P.M. at the Harrisburg, Pennsylvania YWCA; 3.) the grandparents, Gary L. and Theresa M. Statler are permitted to have telephone contact with Logan Bishop Statler when his father, Robert Bishop Provins, is exercising periods of partial custody on Wednesday evenings, Thursday evenings and Sundays. fWatrfft3 ~nri'/ Robert Bishop Provins n!s~~'E~~~ /~ .~e ert ___ eg Intern ,,/I d c. aw ttmlc . ~ ~ (;J{;J0A, Q)O .+t-h,~ .A~.g,,~ Amanda Lynn Statler ItvV\ AP,n Z 2002 AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, Defendant : CIVIL ACTION - LA W : IN CUSTODY GARY L. & THERESA M. STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this i {..,~ay of i<l '~.J '. I , 2002, upon consideration of the attached Custody Co~ is ordered and directed as follows: 1. The prior Order of Court dated January 23, 2002 is hereby vacated. 2. The Mother, Amanda Lynn Nicole Statler, and the Father, Robert Bishop Provens, shall have shared legal custody of Logan Bishop Statler, born May 17, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. custody: Father shall have the following periods of unsupervised partial physical A. Every Wednesday and Thursday from 5:00 p.m. to 8:00 p.m. Father shall pick up the Child at daycare for these two weekly periods and return the child to Mother's residence. B. Beginning April 14, 2002, alternating Sundays from 9:00 a.m. to 5:00 p.m. 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. 5. Neither party shall permit the Child to have contact with any member of Mother's family, except as provided herein. 6. Father shall be responsible for all transportation for his periods of custody. 7. Father shall provide dinner for the Child on Wednesday and Thursday evenings and appropriate meals on Sundays, 8. Father shall knock on Mother's door before entering her home. 9. Father shall keep Mother's unlisted telephone number confidential. 10. Father shall investigate and consider attending a parenting class, 11. Father shall be entitled to one phone call with the child weekly. 12, Grandparents shall have supervised visitation with the child at the Carlisle YWCA on the third Saturday of every month for two hours. In the event the YWCA cannot accommodate this time, the parties shall set a mutually agreeable day and time to allow for a two hour supervised visit once a month, 13. Transportation of the child for Grandparent's visit shall be the responsibility of the Mother. 14, 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, the terms of this Order shall control. Another Condliation Conference is scheduled for July 3, 2002 at 8:30 a.m. BY THE COUR.T, J. J cc: ."comas J. Williams, Esquire, co~sel for Mo~her . . :/Eiisabeth Rowley, certified legal mtem, Family Law Chmc ILucy Johnston Walsh, Esquire, counsel for Father i'thony T. McBeth, Esquire, counsel for Grandparents .~ t~ f'( ~S OY .n-D?" 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. S4904 relating to unsworn falsification to authorities. Date: S ( 2:5:>-/O!:>- 0Y>-1)hJffi~ Robert Bishop Provins, Father, Petitioner -b b ~ ~() ~ v' - l<v ~ --t. --.{\ f' 00 () ~ o \ () (.- ~ ~ C"rl ~_, z;: M2 G-) -:IT...!....: co) :;'~ "r: l.<r) :: ~':'1 -u .;_~,~'-') ::::--')1''' -:7 <~ ~1=" ~Q u:> AMANDA LYNN NICOLE STATLER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-5833 CIVIL ACTION LA W ROBERT BISHOP PROVINS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 13, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumherland County Courthouse, Carlisle on Tuesday, October 11, 2005 at 9:30 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. 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: Isl Tacqueline M. Vernev, Esq. Custody Conciliator .r/ - 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 A TTORNEY AT ONCE, IF YOU DO NOT HA VE 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) 249-3166 -rf~ flp ~ ~ ~ 50nl 'b - Ii' ~ flP~ rryli, 5Y"/J/ - !J o..ul7J ~ ~~ 11M; f1() 5"./1//; . , I"'l"(' \1,";\ ~_, (" '0 ",". "\\\-17 -",.I _ u ---------- GARY L. STATLER AND THERESA M, STATLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v, 02-826 CIVIL ACTION LA W AMANDA LYNN NICOLE STATLER, ROBERT BISHOP PROVINS, AND BRIAN DEAVEN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 13, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M, Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 11, 2005 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 present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or penn anent order, The court hereby directs the parties to furnish any and all existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: isi Jacqueline M. Verney. Esq. Y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For infiml1ation about accessible facilities and reasonable accommodations available to disabled individuals having busincss before thc court, please contact our office, All arrangcments 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 HA VE 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) 249-3166 . rf (j:~ GP ~ ~ ~ ,SO';;Ij? ~ ~ ~ h!u;>ONj ~ #P 'P- ~ 4; 'P7J Sf?'hf'(? C t' .c I.' -J Ii I J:"'; ~:DD2 ,,~V'V . ., . "..'._', ... ..!:~) ...J '~, V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001 - 5833 CIVIL TERM / AMANDA LYNN NICOLE STATLER, Plaintiff ROBERT BISHOP PROVINS : IN CUSTODY Defendant GARY L. STATLER and THERESA M, STATLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, : NO, 2002 - 0826 CIVIL TERM AMANDA LYNN NICOLE STATLER, ROBERT BISHOP PROVINS, and BRIAN DEA VEN, : IN CUSTODY Defendants AFFIDAVIT OF SERVICE AND NOW, this September 28,2005, I, Jane Adams, Esquire, hereby certify that on September 12, 2005, a certified true copy of the PETITION TO MODIFY CUSTODY was served, via certified mail, restricted delivery, return receipt requested, addressed to: Amanda and Brian Deaven 3 12 Pine Rd. Mount Holly Springs, Pa. 1701 SENDEH t(){\"lPlf rF rHI ,[( rlOf, ~ro'WPLETi IHI f( Ij()~, ^, I"l/II, . 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: ~t-\;ht~ :S\-'J- t'~ ~ lYU. ~ ~)..,..--r ;9A: \ 'I 6Ic,'5 3. Sefvlce Type .Ji:ftertlfied Mall 0 Express Mall r. D--Aegistered 0 Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restrlcted Delivery? (Extra Fee) 0 Yes 2. _N...- (TllInSfer from service Iobe/) PS Form 3811, FebrulllY 2004 7004 1350 0003 7288 4752 Domestic Return Receipt 102595-02-M-154Q e Adams, Esquire , No, 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 A HORNEY FOR ROBERT PROVINS .........-- o ;;:; ~ ~ '-" tJ.?~ (" -0 ~6 , ~ .-. :2 q.. ::?-<' -..... .....--::: f" ~ -<1''23 ~;:!~?.. tl, --"'1" ;_~7J '-""'"1:1 ';3\ 'V ~ .- ..", .-,,'- ~, .- .. '-" -s:> - V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001 - 5833 CIVIL TERM / AMANDA LYNN NICOLE STATLER, Plaintiff ROBERT BISHOP PROVINS : IN CUSTODY Defendant GARY L. STATLER and THERESA M, STATLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO, 2002 - 0826 CIVIL TERM AMANDA LYNN NICOLE STATLER, ROBERT BISHOP PROVINS, and BRIAN DEA VEN, : IN CUSTODY Defendants AFFIDAVIT OF SERVICE AND NOW, this September 28, 2005, I, Jane Adams, Esquire, hereby certify that on September 21,2005, a certifietl 'rue copy ofthe ORDER SETIING A CUSTODY HEARING was served, via certified mail, restricted delivery", return receiotreauestetb,ddressed to: Amanda and Brian Deaven 312 Pine Rd, Mount Holly Springs, Pa, 17065 . 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 mallpiece. or .on the front If space permits. 1. Article Addressed to: x"- o Agent o Addressee B. Received by (Printed Name) C. Date of 0eI~ '--. ~t-l ~ 9.Zi-<, D. Is delivery address different from Item 17 0 Yes If YES, enter delivery address below: 0 No ~+-~ :?> \::2.., "'~ (:;>....j M.\- ~~.~? \ '1. ~1c.S- 3. Service Type tx;ortlfied Mall o Registered o Insured Mall Cl Exp~s Mall o Return Receipt for MerchandIse DC,Q,D, 4. Restricted Dellvef)'? (Extra Fee) 0 Yes 2. Article Number (Tiansfer from service label) PS Fonn 3811 , February 2004 7003 1010 0004 7818 6985 Domestic Return Receipt 1025Q5.02-M-1540 J e Adams, Esquire .0, No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR ROBERT PROVINS o c:;: g c.Y' r/) f" -';:; N v::> '" , ~::) ,-- :!1 ....'. 9n ::2."1:1 rr\? ort"; :''1' ;:-':\c) -:::~',j. --(, ',..-n ,'20 --"o~-l'1], 9, -,.,. ~ - .. <.f\ ..0 v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001 - 5833 CIVIL TERM ./ AMANDA LYNN NICOLE STATLER, Plaintiff ROBERT BISHOP PROVINS : IN CUSTODY Defendant GARY L. STATLER and THERESA M. STATLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, : NO, 2002 - 0826 CIVIL TERM AMANDA LYNN NICOLE STATLER, ROBERT BISHOP PROVINS, and BRIAN DEA VEN, : IN CUSTODY Defendants AFFIDAVIT OF SERVICE AND NOW, this October 5, 2005, I, Jane Adams, Esquire, hereby certifY that on September 29, 2005, a certified true copy of the PETITION FOR MODIFICATION AND ORDER SETTING A CUSTODY HEARING was served, via certified mail, restricted delivery, return receipt requested, addressed to: Gary and Theresa Statler 170] Spring Rd. Carlisle, Pa. 17013 . 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 mail piece, or on the front if space permits. 1. Article Addressed to: D. Is delivery address different from Item 1? If YES. enter delivery address below: D No ~4-~ ~'lO\ ~~_j ~I PA-\1bL3 3. Service Type .tJ..certified Mall 0 Express Mall "-meglsterecl D Return ReceIpt for Merchandlse o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number monster from service labeO PS Fonn 3811, February 2004 7003 1010 0004 7818 7012 Domestic Return Receipt 102595-Q2-M-1540 dams, Esquire ,0, 0, 79465 outh Pitt Street Carlisle, Pa, 17013 (717) 245-8508 ATTORNEY FOR ROBERT PROVINS c :2 r-> = = c.n o -, , ' o -n --1 ::I:-n rT1c:, _,) ~:.-l -_'J'-} \:jCf, i;;~S~~ sr ", db '< I Ul -a -"_C< :r::- S" r-:r-"'~r--<<.T:..7''''''''''.~;''.~'~.' . ,,--,..~ -........' .,I. v --~.. 'Y AMANDA LYNN NICOLE STATLER, Plaintiff /Respondent . NC V I I; ,!OIl5 : IN THE COURT OF COMM01iliJ&OJ;:=?L=~1 : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-0826 AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of tV 0\1 _ ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated June 28, 2002 and April 16, 2002 shall remain in full force and effect with the following modification. 2. Father shall have the following periods of partial physical custody: A. Beginning November 12, 2005 alternating Saturdays and Sundays from 9:00 a.m. to 7:00 p.m. B. Once Father has exercised four such weekends, he shall have partial physical custody of the child on an alternating weekend schedule from Saturday at 9:00 a.m. to Sunday at 7:00 p.m. C. Thanksgiving: Father shall have partial physical custody from 4:00 p,m. to 8:00 p.m, D, Christmas: Father shall have partial physical custody of the child on Christmas Eve from 3:00 p.m. to 10:00 p,m. and Christmas Day from 4:00 p.m. to 7:00 p.m, E. Such other times as the parties agree. 3. Father shall be responsible for all transportation. Mother is only required to wait 15-20 minutes for Father to arrive for pick up. 4. Father shall keep Mother's telephone number confidential. "j /',H<::("h --:~"',;nJ ZS:f: Hd 0 I 1\001 SOOZ ^UVIC;-,;C+L~,';d3 3H1 jO 3:JH::O 'OJlL:l 5. Father shall not permit the child to have contact with Mateplal Grandparents except as provided in the previous Orders. 6. This Order is entered pursuant to an agreement of Mother and Father at a Custody Conciliation Conference. They may modifY the provisions of this Order by mutual consent, in the absence of mutual consent, the terms ofthis Order shall control. Either party may request another Conciliation Conference within two months from the date of this Order. BY THE COURT, J. J. cc:~Adams, Esquire, counsel for Father ,ylZarol J. Lindsay, Esquire, counsel for Mother ":C' "!c;"" C'E 1 V 1>, ) j.. "t, J '-.-./._ .....-1 ..... .J,!._ N()V 0 8 Z005 AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEA~ QF{: fY::, cj __ Plaintiff /Respondent : CUMBERLAND COUNTY, PENNSYLVANL.\ f=== V. : No. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, DefendantlPetitioner : CIVIL ACTION - LAW : IN CUSTODY GARY L. & THERESA M. STATLER : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2002-0826 CIVI TERM AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley OIer, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Logan Bishop Statler May 17, 1998 Mother 2. A Conciliation Conference was held in this matter on November 7, 2005. Father, Robert Bishop Provins, appeared with counsel, Jane Adams, Esquire. The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Carol J. Lindsay, Esquire. The maternal Grandparents, Gary 1. and Theresa M. Statler appeared pro se, 3. Prior Orders of Court were entered by the Honorable J. Wesley Oler, Jr. dated June 28, 2002 and April 16, 2002. Those Orders provide for shared legal custody and for Mother to have primary physical custody with Father having periods of partial physical custody. Grandparents have supervised visits one day per month for two hours. 4. The Mother and Father agreed to entry of an Order in the form as attached, No modification was made to the Order relating to the Grandparents, ,,<" ,. ,<'-- :t---<.--"t--'/_____--'-----__.( !'" i l' K-__ '-____~----->::_, Date )acqueline M. Verney, Esquire "?> Custody Conciliator ~ -";J r r AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF <I Plaintiff /Respondent : CUMBERLAND COUNTY, PENNSYL VANIA V. : No. 2001-5833 CIVIL TERM ROBERT BISHOP PROVINS, DefendanVPetitioner : CIVIL ACTION. LAW : IN CUSTODY GARY L. & THERESA M. STATLER : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2002-0826 CIVI TERM AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of February, 2006, the parties having not requested another Conciliation Conference within two months of the prior Order of Court, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 0 <-"' () r,-::' ~ ,"" --n <eJ' '"" f""\ 0,:.1 I W -.., -<, -"' 1'.) Q:)