HomeMy WebLinkAbout01-05833
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J~ 2002
AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS 0"" N .
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
~ NO. 2001-5833 CIVIL TERM ~
: IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant
GARY L. 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 DEA YEN,
Defendants
ORDER
AND NOW, this zc:, tI. day of ~-..lt 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:
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AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CML ACTION - LAW
~ NO. 2001-5833 CIVIL TERM .,.".-
: IN CUSTODY .
ROBERT BISHOP PROVINS,
Defendant
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
BRIANDEAVEN,
Defendants
STIPULATION OF THE PARTIES REGARDING MODIFICATION OF
APRIL 16.2002 ORDER
WHEREAS, because of changed circumstances, the Parties desire to amend the terms ofthe
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 pennitted to have telephone contact
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with Logan Bishop Statler when his futher, Robert Bishop Provins, is exercising periods of partial
custody on Wednesday evenings, Thursday evenings and Sundays.
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esa M. Statler
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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 Jacqueliue M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on . Tnesday, 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 auy 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
Jacqueline M. Verney_ Esq. ~
Custody Conciliator
The Court of C01nmon Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of I 990. 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 SHOill"D TAKE lHIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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
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AMANDA LYNN NICOLE STATLER,: IN TIm COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: CIVIL ACTION - LAW
: NO. 2001-5833 CML TERM .,,/
: IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
GARYL. STATLER and
THERESA M. STATLER,
Plaintiff
v.
: NO. 2002-0826
AMANDA LYNN NICOLE STATLER, :
ROBERT PROVINS and : IN CUSTODY
BRlANDEAVEN,
Defendants
QRDER OF COWT
AND NOW, , upon consideration of the attached Complaint, it is
hereby directed that the parties and their respective counsel appear before
, the Conciliator, on the _ day of , 2002,
at__.m., at the location of , Pennsylvania at
a Pre-Hearing Custody Conference. At such Conference, an effurt 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.
FOR THE COURT:
By:
Custody Conciliator
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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 infurmation about accessible facilities and reasonable
accommodations available to disabled individuals baving 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 A LAWYER 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, PA 17013
(717) 249-3166
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AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: CML ACTION - LAW
ROBERT BISHOP PROVINS,
Defendant
: NO. 2001-5833 CIVIL TERM
: IN CUSTODY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. STATLER and
THERESA M. STATLER,
Plaintiff
: CIVIL ACTION - LAW
v.
: NO. 2002-0826
AMANDA LYNN NICOLE STATLER, :
ROBERT PROVINS and : IN CUSTODY
BRIANDEAVEN,
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 01er, 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
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fucility could not and would not arrange for such supervised visitations as contemplated by the April
16,2002 order.
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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 fucility also serves as a Rape Crisis Center, and
representatives of the Carlisle YWCA believe that assisting Mr. Statler in such circumstances could
costs that fucility some of its funding.
6. Because of other difficulties 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 filet 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 family is involved with supervised visitation, there are separate parking fucilities and separate
entrances for the parties involved in the visitation, that the fucility will not charge any party for the
supervised visitation and that personnel of that fucility will voluntarily provide summary statements
to the parties' counsel describing the events of and quality of the visit.
8. Defendant Amanda Lynn Nicole Statler, through her counsel, has been informed of all of
these filets (including the absence oftelephone provisions in the April 16 order) and arbitrarily refuses
to agree to either supervised visitation at the Harrisburg YWCA or any telephone contact.
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9. Through the telephone conversation with Ian Booty as descnbed 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 result of the difficulties and intransigence described 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 1 0, 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.
ny T. McB
Attorney fur Pet'
407 North Fron St., First Floor
Harrisburg, PAl
(717) 238-3686
Supreme Court J.D. # 53729
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AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: CIVIL ACTION - LAW
ROBERT BISHOP PROVINS,
Defendant
: NO. 2001-5833 CIVIL TERM
: IN CUSTODY
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
BRIANDEAVEN,
Defendants
CERTIFICATE OF SERVICE
I, Anthony T. McBeth, Esquire, hereby certify that I have served to persons listed below with
the attached document, by first class mail, postage pre-paid, on the date indicated below:
Thomas J. Williams, Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, P A 17013
(Attorneys for Amanda Statler)
Elisabeth L. Rowley, Certified Legal Intern
Family Law Clinic
45 North Pitt Street
Carlisle, P A 17013
(Attorneys for Robert Bishop
thonyT.M e Esq.
Attorney for P itio rs
407 North Fron First Floor
Harrisburg, PA 17101
(717) 238-3686
Supreme Court LD. # 53729
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AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
. .
: NO. 2001-5833 CIVIL TERM
: CIVILA-CTlON- LAW
: IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant
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 Jl,-fh day of ,2002, upon
consideration of the attached Custody Concilia ion Report, 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 il.om 9:00.a.m. to 5:00 p.m.
5. Neither party shall permit the Child to h~ve 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"
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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.
J I. 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.
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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 Iestlmony whereof, 1 here unto set myhand
and th sealofsaid our at arlisle, Pa.
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APR k2002
AMANDA LYNN NICOLE STATLER, : IN THE COVRT OF COMMON PLEAS OF
Plaintiff : CUM.BERLAND 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 COI)NTY 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 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 cllstody and for Mother to
have primary physical custody with Father having periods of pat1ial physical cllstody.
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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 cllstody 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.
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Date
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que ne M. Verney, Esquire
Custody Conciliator
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VERIFICATION
We, Gary L. Statler and Theresa M. Statler, Plaintiffs in the foregoing action, verify that the
mcts set forth in the attached document are true and correct to the best of our knowledge,
infurmation 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
Theresa M. Statler
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JUN 2 6 Z002 ~
AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLV ANIA
V.
: NO.2001-5833 CIVIL TERM
ROBERT BISHOP PROVlNS,
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. ~
M. Verney, Esquire, Custody C ciliator
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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,
DefendantlPetitioner
NO. 01 - 5833 CNIL TERM
ORDER OF COURT
AND NOW this '73, r J day of April 2002, a Rule to Show Cause having been
issued and no response having been filed, it is hereby Ordered that DefendantlPetitioner's
Objections to Subpoena is granted. The Subpoena to Produce Documents or Things for Discovery
Pursuant to Rule 4009.22 is hereby quashed.
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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,
Defendant/Petitioner
NO. 01 - 5833 CIVIL TERM
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes the Defendant/Petitioner 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 1, 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.
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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~rXL( OJ-
. sabeth L. Ro
Certified Legal Intern
~~c/J~
THO S . PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717/243-2968
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AMANDA LYNN NICOLE STATLER,
Plaintif:fJRespondent
: 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 Apri12002, 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.
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FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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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
tI ORDER OF COURT
AND NOW, this I~ ~';y of March, 2002, after careful consideration of Defendant's
"Prelirninary 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 disrnissed for failure to conform to court rules
and for the inclusion of scandalous and irnpertinent 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
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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,
r-:
A'L. Statler
Theresa M. Statler
105 Farm Road
Newville, PA 17241
Pro Se Plaintiffs
~s 1. Williams, Esq.
Ten East High Street
Carlisle, PA 17013-3093
Attorney for Defendant Amanda Lynn Nicole Statler
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~rnas Place, Esq.
45 North Pitt Street
Carlisle, PA 17013
Attorney for Defendant Robert Bishop Provins
~ueline M. Verney, Esq.
Custody Conciliator
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APh^~ 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 t (,., ~ay of ~ ~.J : { , 2002, upon
consideration ofthe attached Custody Conciliation It 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 ofthe 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.
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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
carmot 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 ofthe parties at a Custody
Conciliation Conference. The parties may modify the provisions ofthis 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
Lucy Jolmston Walsh, Esquire, counsel for Father
fthony T. McBeth, Esquire, counsel for Grandparents
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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, PENNSYL VANIA
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:
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 Jolmston 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.
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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/_ /do, -D"2-
Date
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que ne M. Verney, Esquire
Custody Conciliator
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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
PROVINS,
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,
Thornas J. Williams, Esq.
10 East High Street
Carlisle, PA 17013
Attorney for Plaintiff
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Certified Legal Intern
Thornas M. Place, Esq.
Robert E. Rains, Esq.
Lucy Johnston-Walsh, Esq.
Family Law Clinic
45 North Pitt Street
Carlisle, P A 17013
Supervising Attorneys
Attorneys for Defendant
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,
AMANDA LYNN NICOLE STATLER,
PlaintiffiRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant/Petitioner
NO. 01 - 5833 CIVIL TERM
ORDER OF COURT
AND NOW, this
day of March, 2002, upon consideration of
DefendantlPetitioner's Objections to Subpoena, the PlaintiffiRespondent's Subpoena to Produce
Documents or Things For Discovery Pursuant to Rule 4009.22 is quashed.
BY THE COURT
J.
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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,
DefendantlPetitioner
NO. 01 - 5833 CIVIL TERM
OBJECTIONS TO SUBPOENA
DefendantlPetitioner, 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 PlaintifflRespondent in this matter has not obtained such special order of court,
nor asserted any basis for such a special order of court.
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WHEREFORE, the DefendantlPetitioner requests that the Subpoena to Produce
Documents or Things For Discovery Pursuant to Rule 4009.22 be quashed.
Date: cyln/ ()p-
Elisabeth L. ley
Certified Legal Int
__0&
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
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Main OffICe
4940 Disston Street
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Phone: (215) 335.3212
Fax: (215) 338.2980
E-maU Address: legal@medleg.com
Jefferson Bldg., Suite 926
1015 Chestnut Street
PhUadelphia, Pa. 19107
Mar 01, 2002
TERRI HENNING, ESQUIRE
45 N PITT ST
CARLISLE PA 17013
Re: ROBERT BISHOP PROVINS
Caption: STATLER v. PROVINS
Our File #: 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 .
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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
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-4907
By: Jacqueline ciarrocchi
Ene(s}:. Copy ofsubpoena(s}
Counsel return eard
File #: H284413
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ClJMM')NWFALTH OF PENNSYLVANIA
COUNrY OF aJMBERIAND
STATLER
VS.
File No.
?nnT 5833
PROVINS
SUBPOENA TO PRODUCE DOCLNENTS OR lH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
. . . '
FOOD STORES, 255 S SPRING GARDEN ST, CARI.ISLE PAn013
PRR ~()T\l1\TRT. DF.P ARTMRNT .
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!; or things:
SEE ATTACHED ADDENDUM
GIANT
:A'J''l'lIT.
TO:
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 sub"poena,togetherwit!1 the certificate. of caTllliance, . to the party making thi,.
requ'est at the . address listed above. You have theright to seek in advance the reasonablE
cost of preoaring the oopiesor producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~entv
(20) days after its serv~ce, the party serving thh "ubpoena may seek a court orde:.
~elling YOlJ to carply with it.
lH I S SUBPOENA WAS I SSUED AT lHE REQUEST OF lHE FOLLo.Y 1 NG PERSON:
NAME: T~()M:A$ .T WTLLIAMS, ESQ
AOORESS :
MART50N BEARDORFF
CARLISLE, PA 17013
215-335-3212
TELEPHONE:
SUPREI'E CCUlT < ID #
ATTORNEY FOR:
PLAINTIFF
BY THE <XXJRT:
M284413-01.
03/22/02
Prothonotary/Clerk, Civi 1 Division
DATE:
5.eal of the Court
Deputy
(Eff. 7/97)
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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 j .. . ATTENDANCE SHEETS,. ANY AND ALL MEDICAl, RECORDS AND REPORTS
AND PRE-EMPLOYMENT i?HYSICALS,WORKME~'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, A~DANY OTHER INFORMATION PERTAINI~G TO:
NAME: ROBERT BISHOP PROVINS
ADDRESS: 12 MOUNT ROCK RD NEWVILLE PA
. "" .
, . . . . . .
. . .
.. .
. . . .' .
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE A1TACHED HERETO: I hereby certify as custodian of
records that, to the best of my ~~ow1edge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS A V AILABLE: 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
. ( ) X-RAYS
( ) PATIENT BILLING
( ) RECORDS I XRAYS have been destroyed
Date
Authorized s~gnature for
GIANT FOOD STORES
CUMBERLAND
M284413-01
*** SIGN AND RETURN THIS PAGE ***
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AMANDA LYNN NICOLE STATLER,
Plaintif:IJRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION-LAW
: IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant/Petitioner
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
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tme and correct copy ofDefendant/Petitioner's Objections to Subpoena on Thomas J. 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.
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45 North Pitt Street
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717-243-2968
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AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : C1JMBERLAND COUNTY,PENNSYLV ANIA
V.
: NO.2001-5833 CIVIL TERM
ROBERT BISHOP PROVINS,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this &, tI. day of "0 c..u-.k.cJ ,2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Mother shall have primary physical custody of Logan Bishop Statler, 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 permit the child to have contact with the child's
maternal grandparents.
5. The parties shall retum to a Conciliation Conference scheduled for
December 19, 2001 at 8:00 a.m.
BY THE COURT,
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J.
cc: Thomas J. Williams, Esquire, counsel for Mother
Gina Carnes, certified legal intern, Family Law Clinic
Teri Henning, Esquire, counsel for Father
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AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYL VANIA
V.
: 2001-5833 CIVIL TERM
ROBERT BISHOP PROVINS,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
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 ofthis
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 21, 2001.
The Mother, Amanda Lynn Nicole Statler, appeared with counsel, Thomas J. Williams,
Esquire. Father, Robert Bishop Provins, appeared with counsel, Gina Carnes, certified
legal intern from the Family Law Clinic, along with Teri Henning, Esquire.
3.
The parties agreed to entry of an Order in the form as attached.
11-;; 7 -0 1
Date
Ja ueline M. Verney, Esquire
Custody Conciliator
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AMANDA LYNN NICOLE STATLER,
Plaintiff1Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION-LAW
: IN CUSTODY
ROBERT BISHOP PROVINS,
Defendant/Petitioner
NO. 01 - 5833 CIVIL TERM
ORDER OF COURT
AND NOW, this
day of March, 2002, upon consideration of
DefendantlPetitioner's Objections to Subpoena, the Plaintiffi'Respondent's Subpoena to Produce
Documents or Things For Discovery Pursuant to Rule 4009.22 is quashed.
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AMANDA LYNN NICOLE STATLER,
PlaintifflRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION-LAW
: IN CUSTODY
ROBERT BISHOP PROVINS,
DefendantlPetitioner
NO. 01 - 5833 CIVIL TERM
ORDER OF COURT
AND NOW, this
day of March, 2002, upon consideration of
DefendantlPetitioner's Objections to Subpoena, the PlaintifflRespondent's Subpoena to Produce
Documents or Things For Discovery Pursuant to Rule 4009.22 is quashed.
BY THE COURT
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AMANDA LYNN NICOLE STATLER,
PlaintifflRespondent
MAR ~nD2
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION-LAW
: IN CUSTODY
ROBERT BISHOP PROVINS,
DefendantlPetitioner
NO. 01 - 5833 CIVIL TERM
ORDER OF COURT
AND NOW, this
day of March, 2002, upon consideration of
DefendantlPetitioner's Objections to Subpoena, the PlaintifflRespondent's Subpoena to Produce
Documents or Things For Discovery Pursuant to Rule 4009.22 is quashed.
BY THE COURT
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AMANDA LYNN NICOLE STA1LER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AN1A
V.
01-5833 CIVIL ACTION LAW
ROBERT BISHOP PROVINS
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, October 19, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Veruey, Esq. , the conciliator,
at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on Mouday, November 05, 2001 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 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;Verney. Esq. Vr^
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Custody Conciliator
The Court of Common Pleas of Cumberland County is r~~ed by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facihties 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 TOYOURATIORNEY 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
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F:\FlLES\DATAFILE\Gendoc,cur\97813-com.lItde
Created: 10/02/01 02::t2:27 PM
Revised: 1?J08fOlll:<\.3:48AM
AMANDA LYNN NICOLE STATLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
01- j-UJ
CIVILACTION-LAW
ROBERT BISHOP PROVINS,
Defendant
IN CUSTODY
ORDER OF COURT
(
AND NOW, this day of , upon consideration of the attached Complaint,
it IS hereby directed that the parties and their respective counsel appear before
, the conciliator, at
on the ~ day of , , at .m. for a Pre-Hearing
Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter
into a temporary order. All children age five or older may also be present at the conference. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By:
Custody Conciliator
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 hearing or business before
the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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AMANDA LYNN NICOLE STATLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
01- 5Y3.3
CIVlLACTION-LAW
ROBERT BISHOP PROVINS,
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
Jiving 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
Mother
Sister
Katie Provins
6. The parties have not participated in previous litigation concerning the custody of the
child in this court or any court.
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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 enviromnent 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.
MARTSON DEARDORFF WILLIAMS & OTTO
By (~ 'v\,~
Thomas J. Wil. s, Esquire
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiffs
Date: October 8, 2001
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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 of the 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.
O.r^a~~ ~
Amanda Lynn Nicole Statler
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AMANDA LYNN NICOLE STATLER,
PlaintifflPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5833 CIVIL ACTION - LAW
ROBERT BISHOP PROVINS,
Defendant/Respondent
IN CUSTODY
ORDER
AND NOW, this _ day of March, 2002, upon consideration of Plaintiff's Petition for
Contempt, it is referred to Jacqueline M. Veryney, Esquire, Conciliator for a conference solely as
to the issue of whether Respondent be judged in contempt for failure to maintain Petitioner's unlisted
telephone number in confidence in violation of the Order of January 23, 2002.
BY THE COURT,
J. Wesley Oler, Jr., J.
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F:\FILESIDA T AFILE\Gendoc,cur\97813-pet.lltde
_Created: IOfOU0102:22:27PM
Revised: 02/27f0209:10:03AM
9781.3
AMANDA LYNN NICOLE STATLER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5833 CNIL ACTION - LAW
ROBERT BISHOP PROVINS,
DefendantJRespondent
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes Plaintiff, Amanda LyunNicole Statler (hereinafter, "Petitioner"), by and
through her attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, and in support of this
Petition, avers as follows:
1. Petitioner is estranged from her parents as a result of a history of sexual abuse by her
father and a condonation of same by her mother.
2. Last year, Petitioner revealed this incestuous relationship to close friends and an
investigation was begun by the Pennsylvania State Police.
3. At about the time this investigation began, Petitioner felt pressure from other family
members to recant her truthful statement and "get on" with her life. With these, Petitioner received
anonymous telephone calls, hang ups when they were answered, with no Caller I.D.
4. As a result of these telephone calls and the family pressure, Petitioner changed her
telephone number in early 2002 to make it unlisted.
5. At a Conciliation Conference on January 16, 2002, upon the request of Respondent,
Petitioner disclosed hernew (unlisted) telephone number upon the clear and strict understanding that
he would maintain it in confidence and not disclose it to anyone, particularly members of Petitioner' s
family. This confidentiality requirement was incorporated in the Court's Order of January 23, 2002
which resulted from the Conciliation Conference. A copy ofthe January 23, 2002 Order is attached
hereto and marked as Exhibit "A."
6. Within a week of furnishing Respondent with her telephone number, Petitioner
received a call from her brother, Michael Statler, a member of the U.S. Navy stationed in another
part of the country. Michael was calling long distance and, upon inquiry, refused to disclose to
Petitioner where he obtained her telephone number.
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7. Michael has previously interceded with Petitioner on behalf of her parents despite
being asked not to do so by Petitioner.
8. Petitioner has been advised, believes and therefore avers, that Respondent has at least
been in communication with her parents and likely has been acting in concert with them with regard
to this custody matter, as well as other related matters.
9. The only way Petitioner's brother could have obtained her telephone number is from
Respondent and this would have been in direct contravention of the agreement and the Custody
Order.
WHEREFORE, Petitioner prays Your Honorable Court to:
a. Find Respondent in contempt for failing to maintain her telephone number
in confidence;
b. Impose such penalty for said contempt as the Court shall deem appropriate;
and
c. Order and direct Respondent to reimburse Petitioner for the cost and expense
of enforcing the Court's Custody Order.
Respectfully submitted,
MARTS ON DEARDORFF WILLIAMS & OTTO
By .L-'<- ~ 'NdD."
Thomas J. Willi , EsqUire
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff/Petitioner
Amanda Lyun Nicole Statler
Date:;rJOM.lt 'f, Zff&z..
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AMANDA LYNN NICOLE STATLER. : IN THE COURT OF COMMON PLEAS OF
Plalntill' : CUMBERLANDCOUNTY,PENNSYLVANIA
V.
.
.
: NO.2001-5833 CIVIL TERM
ROBERT BISHOP PROVINS,
Defe.da.t
.
.
: CIVIL ACTION - LAW
.
.
: IN CUSTODY
Q.QDEROF COURT
AND NOW, this DrJ day ofj alu.a.r 2002, upon
consideration of the attached Custody Conciliation ~ it is ordered and directed as
follows:
) 1; The prior Order of Court dated December 6, 2001 is hereby vacated and
f1 replaced with this Order.
2. 'The Mother, Amanda Lynn Nicole Statler, and the Father, R.o~ Bishop
Provens. shall have shared legal custody of Logan Bishop Statler,' bom 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 affectl1ig the Chila~ general Well.being
incb.d.ng. but not limited to, all decisions regarding his health, education and religion.
3. . Mother shallliave ~ physical custody of the Child.
4. Father shall have the following periods of unsupervised partial physical
custody:
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.
i )
S. 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 forthe Child on Wednesday and Friday
evenings and appropriate meals on Saturdays.
, .
8. .'. Father shall knock on Mother's door before enteritig her home.
'c
9.
Father shall keep Mother's unlisted telephone number confidential.
EXHIBIT "A"
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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.
)
ct: Thomas J. Williams, Esquire, counsel for Mother '
Elisabeth Rowley, certified lega1l intern. Family Law Clinic
, Thomas Place, Esquire. counsel for Father
-' .
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,
VERlFICATION
The foregoing Petition for Contempt is based upon information which has been gathered by
my counsel in the preparation of the lawsuit The language of the docwnent is that of counsel and
not my own, I have read the docwnent and to the extent that it 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 of the docwnent is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of18 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.
J/Yl/JJd~~ 1Ir~~
Amanda Lyrm Nicole Statler
F:\FILES\DATAFILE\Gendoc.cun97813-pet.1
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CERTIFICATE OF SERVICE
I, Tricia D, Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certifY that a copy of the foregoing Petition for Contempt was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Terri Henning, Esquire
45 North Pitt Street
Carlisle, P A 17013
MARTSON DEARDORFF WILLIAMS & OTTO
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Tnc aD, Eckenroad ' '
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
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AMANDA LYNN NICOLE STATLER,
Plaintift7Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5833 CIVIL ACTION -LAW
ROBERT BISHOP PROVINS,
DefendantJRespondent
IN CUSTODY
ORDER
AND NOW, this _ day of March, 2002, upon consideration of Plaintiff's Petition for
Contempt, it is referred to Jacqueline M. Veryney, Esquire, Conciliator for a conference solely as
to tI1e issue of whether Respondent be judged in contempt for failure to maintain Petitioner's unlisted
telephone number in confidence in violation of the Order of January 23,2002.
BY THE COURT,
J. Wesley Oler, Jr., J.
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F:\FILES\DAT AFlLB\Gendoc.cur\97813-pet.lItdc:
Created: lOf02l0102:22:Z7PM
Revised: 02127/02 09:10:03 AM
978JJ
AMANDA LYNN NICOLE STATLER,
Plaintiffi'Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5833 CIVIL ACTION - LAW
ROBERT BISHOP PROVINS,
Defendant/Respondent
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes Plaintiff, Amanda Lynn Nicole Statler (hereinafter, "Petitioner"), by and
through her attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and in support of this
Petition, avers as follows:
1, Petitioner is estranged from her parents as a result of a history of sexual abuse by her
father and a condonation of same by her mother,
2. Last year, Petitioner revealed this incestuous relationship to close friends and an
investigation was begun by the Pennsylvania State Police.
3. At about the time this investigation began, Petitioner felt pressure from other family
members to recant her truthful statement and "get on" with her life. With these, Petitioner received
anonymous telephone calls, hang ups when they were answered, with no Caller LD.
4. As a result of these telephone calls and the family pressure, Petitioner changed her
telephone number in early 2002 to make it unlisted.
5, At a Conciliation Conference on January 16, 2002, upon the request of Respondent,
Petitioner disclosed her new (unlisted) telephone number upon the clear and strict understanding that
he would maintain it in confidence and not disclose it to anyone, particularly members of Petitioner' s
family, This confidentiality requirement was incorporated in the Court's Order ofJanuary 23, 2002
which resulted from the Conciliation Conference. A copy of the January 23,2002 Order is attached
hereto and marked as Exhibit "A."
6, Within a week of furnishing Respondent with her telephone number, Petitioner
received a call from her brother, Michael Statler, a member of the U.S. Navy stationed in another
part of the country, Michael was calling long distance and, upon inquiry, refused to disclose to
Petitioner where he obtained her telephone number.
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7. Michael has previously interceded with Petitioner on behalf of her parents despite
being asked not to do so by Petitioner,
8. Petitioner has been advised, believes and therefore avers, that Respondent has at least
been in communication with her parents and likely has been acting in concert with them with regard
to this custody matter, as well as other related matters.
9. The only way Petitioner's brother could have obtained her telephone number is from
Respondent and this would have been in direct contravention of the agreement and the Custody
Order,
WHEREFORE, Petitioner prays Your Honorable Court to:
a. Find Respondent in contempt for failing to maintain her telephone number
in confidence;
b, hnpose such penalty for said contempt as the Court shall deem appropriate;
and
c, Order and direct Respondent to reimburse Petitioner for the cost and expense
of enforcing the Court's Custody Order.
Respectfully submitted,
MARTSON DEARDORFF WILLIAMS & OTTO
By 1"k,,~ L(i~.&-.
Thomas J. 'lams, Esqmre
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffi'Petitioner
Amanda Lynn Nicole Statler
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AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEAS or
PlalDtill' : CUMBERLANDCOUNTY,PENNSYLVANIA
V.
.
.
: NO. 20ltl-5833 CIVIL TERM
ROBERT BISHOP PROVIN5.
Defeadaat
:
: CMLACTlON-LAW
.
.
: IN CUSTODY
Q.RDER O.F COURT
AND NOW. this J..;3rJ day ofjalu.a.r 2002, upon
consideration of the attached Custody Conciliation it is ordered and directed as
follows:
)
L The prior Order ofCoIIJI't dated December 6, 2001 is hereby vacated and
replaced with this Order.
2. 'The Mother"Amanda Lynn Nicole Statler, and the Father,R.o~Bishop
Provens. shall have shared legal custody of Logan Bishop Statler,' bom 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 afTectiJlg the Chilii~ general Wen-being
including, but not limited to, all decisions regarding his health, education and religion.
" '
. '
3. Mother shall have primary physical custody of the Child.
..
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4.
custody:
A. Every Wednesday ftom 5:00 p.m. to 8:00 p.m. and every Friday ftom 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.
Father shall have the following periods of unsupervised partial physical
s. Neither party shall pennit 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 enteriJig her home.
'r
9.
Father shall keep Mother's unlisted telephone number confidential.
EXHIBIT "An
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10. Father shal1 investigate and consider alfP.I'Idl"g 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 ot'this Older by mutual
consent. the terms of this Older shall control.
')
ct: Thomas J. Willi",,!\, Esquire, counsel for Mother '
Elisabeth Rowley, certified lega1l intem. Family Law Clinic,
; TbnmRII Place. Esquire, counsel for Father '
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VERIFICATION
The foregoing Petition for Contempt 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 document and to the extent that it 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 of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
avennents, I may be subject to criminal penalties.
~~ 1IUd.~
anda Lynn Nicole Statler
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CERTIFICATE OF SERVICE
I, Tricia D, Eckemoad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certifY that a copy of the foregoing Petition for Contempt was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Terri Henning, Esquire
45 North Pitt Street
Carlisle, PA 17013
MARTSON DEARDORFF WILLIAMS & OTTO
~!J~l} 0(&nJ.
l Tnc aD. Eckemoad '
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: fjML "Ii }JJOj.,_
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MAR 0 8 2002 'v0
AMANDA LYNN NICOLE STATLER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
01-5833 CNILACTION -LAW
ROBERT BISHOP PROVINS,
Defendant/Respondent
IN CUSTODY
ORDER
AND NOW, this _ day of March, 2002, upon consideration of Plaintiffs Petition for
Contempt, it is referred to Jacqueline M, Veryney, Esquire, Conciliator for a conference solely as
to the issue of whether Respondent be judged in contempt for failure to maintain Petitioner's unlisted
telephone number in confidence in violation of the Order of January 23, 2002.
BY THE COURT,
J, Wesley Oler, Jr., J.
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MAR 0 8 20021-'0
AMANDA LYNN NICOLE STATLER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5833 CNILACTION -LAW
ROBERT BISHOP PROVINS,
Defendant/Respondent
IN CUSTODY
ORDER
AND NOW, this _ day of March, 2002, upon consideration of Plaintiffs Petition for
Contempt, it is referred to Jacqueline M. Veryney, Esquire, Conciliator for a conference solely as
to the issue of whether Respondent be judged in contempt for failure to maintain Petitioner's unlisted
telephone number in confidence in violation of the Order of January 23, 2002.
BY THE COURT,
J. Wesley Oler, Jr., J.
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AMANDA LYNN NICOLE STATLER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
01-5833 CIVIL ACTION LAW
ROBERT BISHOP PROVINS
DEFENDANT
IN CUSTODY
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
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
"I 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: /s/
Jacqueline M. Vemev, Esq.
Custody Conciliator
.y
-
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990, For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office, All arrangements
must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled
conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 170 \3
Telephone (717) 249-3166
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GARY L, STATLER AND THERESA M,
STATLER
IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
02-826
CIVIL ACTION LAW
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 Jacqueliue M. Veruey, Esq. ,the conciliator,
at 4th Floor, Cumberland Connty 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 pennanent 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 hearin!!.
,
;
FOR THE COURT.
By: /s/
Tacqueline M Vemev. 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] 990, For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office, All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. fF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3 I 66
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AMANDA LYNN NICOLE STATLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
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, PENNSYL V ANlA
Plaintiffs
V,
: NO, 2002 - 0826 CIVIL TERM
AMANDA LYNN NICOLE STATLER,
ROBERT BISHOP PROVINS, and
BRIAN DEA VEN,
: IN CUSTODY
Defendants
ORDER OF COURT
AND NOW, this
day of
,2005, upon
consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear
before
, Esquire, the conciliator, at
, Pennsylvania, on
, the
day of
,2005, at o'clock ,m, for a Pre-Hearing Custody Conference, At such
conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and
narrow the issues to be heard by the court, and to enter into a temporary order, All children five or older may be
present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or
permanent Order,
The court herehy direets the parties to furnish any and all existing Protection from Ahuse orders,
Speeial Relief Orders, and Custody Orders to the eonciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By
Custody Conciliator
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 hearing or business before the court, You must attend the scheduled conference or
hearing,
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER
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 St
Carlisle, Pa, 17013
(717) 249-3166
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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
ClARY L. STATLER and
THERESAM. 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:
1. Robert Bishop Provins, (hereinafter referred to as "Father") is an adult individual
currently residing at 12 Mount Rock Road, Newville, Pa. 17241,
2. Amanda Lynn Deaven, formerly known as Amanda Lynn Nicho1e Statler, (hereinafter
referred to as "Mother"), is currently residing at 312 Pine Road, Mount Holly Springs,
Pennsylvama,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 change in the birth certificate.
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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 specific 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: 0/7'1 (ti5
J e Adams, Esquire
I . No. 79465
4 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR PETITIONER
ROBERT BISHOP PROVINS
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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
GARY L. STATLER <md
THERESA M. STATLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CML ACTION - LAW
v.
: NO. 2002-0826
AMANDA LYNN NICOLE STATLER,:
ROBERT PROVlNS and : IN CUSTODY
BRIAN DEA VEN,
Defendants
ORDER
AND NOW, this zc:,tf. dayof~~ L
, 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:
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AMANDA LYNN NICOLE STATLER,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
ROBERT BISHOP PROVINS,
Defendant
: NO. 2001-5833 CIVIL TERM ~
: IN CUSTODY,
GARY L. STATLER;md
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 ;md : IN CUSTODY
BRIANDEAVEN,
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 1;2 ofthe April 16, 2002 Order is amended to provide that the gr;mdparents,
Gary L. and Theresa M. Statler sha11 have supervised visitation with Log;m 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 gr;mdparents, Gary L. ;md Theresa M. Statler are pennitted to have telephone contact
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with Logan Bishop Statler when his father, Robert Bishop Provins, is exercising periods of partial
custody on Wednesday evenings, Thursday evenings and Sundays.
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Amanda Lynn Statler
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Thomas 1. Wi , Esqmre
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Robert Bishop Provins
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APlM:^2 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 : CIUMBERLAND 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 ~ ~J .; ( ,2002, upon
consideration of the attached Custody Conciliation R port, 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, 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 ofthe 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 retool 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.
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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 ata 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 Mo~her . .
. Etisabeth Rowley, certified legal intern, Farruly Law Chmc
fLu y Johnston Walsh, Esquire, counsel for Father
1thony T. McBeth, Esquire, counsel for Grandparents
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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.
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Robert Bishop Provins, Father, Petitioner
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
; NO, 2001 - 5833 CIVIL TERM /'
AMANDA LYNN NICOLE STATLER,
Plaintiff
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
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, address~~ to:
Amanda and Brian Deaven
312 Pine Rd,
Mount Holly Springs, Pa. 170~
. Complete Items 1, 2, and 3. Also complete
ltern 4 if Restricted Delivery Is desired.
. Print yo()r name and address on the reverse
~o that we,c;:an return the card to you.
. Attach thls~aill to the back of the mailpiece.
or on the frOnt)f space permits.
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2. Article Number
(T""'- from servTce/abeJ)
PS Fonn 3811, February 2004
7004 135D00037288 Lf752
Domestic Return Receipt 102595-02-M-1540 :
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. No, 79465
64 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR ROBERT PROVINS
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO, 2001 - 5833 CIVIL TERM /
AMANDA LYNN NICOLE STATLER,
Plaintiff
V.
ROBERT BISHOP PROVINS
GARY L. STATLER and
THERESA M, STATLER,
V,
: IN CUSTODY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
: NO, 2002 - 0826 CIVIL TERM
AMANDA LYNN NICOLE STATLER,
ROBERT BISHOP PROVINS, and
BRIAN DEA YEN,
: IN CUSTODY
Defendants
AFFIDAVIT OF SERVICE
AND NOW, this September 28, 2005, I, Jane Adams, Esquire, hereby certify that
on September 21, 2005, a certifie<l true copy of the ORDER SETTING A CUSTODY HEARING was served, via
certified mail, restricted delivery, 1'elUm receiotrelillest'eif;,'lIddte~sed to:
Amanda and Brian Deaven
312 Pine Rd.
Mount Holly Springs, Pa, 17065
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. Attach this card to the back of the mailplece,
or .on the front if space permits.
1. Article Addressed to:
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B. .Received by (Printed Name) C. Date of Del~
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2. Miele Number
(Transfer from service label)
PS Form 3811. February 2004
7003 1010 0004 7818 6985
DomestiC: ~eturn Receipt
102595-02-M-1540
J e Adams, Esquire
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4 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR ROBERT PROVINS
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO, 2001 - 5833 CIVIL TERM ./
AMANDA LYNN NICOLE STATLER,
Plaintiff
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
AMANDALYNNN~O~SUT~~
ROBERT BISHOP PROVINS, and
BRIAN DEA YEN,
: 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 I 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 6n the reverse
so that we can return the card to ypu.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
D. Is delivery address dlfferentfrom item 111
If YES" enter delivery address below: 0 No
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3. Service TYPe
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4. Restricted DeliverY? (€xtr'a Fee) 0 Yes
2. ArtIcle 'Number
(1IIonofer /tom seMce label)
PS Fonn3811, February 2004
7003 1010 0004 7818 7012
Domestic Return Receipt
102595-Q2-M-1540
dams, Esquire
,D, 0, 79465
outh Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR ROBERT PROVINS
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AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMO
Plaintiff /Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
NOV 0 R 2005
~
V.
: NO. 2001-5833 CIVIL TERM /
ROBERT BISHOP PROVINS,
DefendantJPetitioner
: CIVIL ACTION - LAW
: IN CUSTODY
GARY L. & THERESA M. STATLER, : INTHE 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 -.1Ml day of rJ 0" ,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 ofthe 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.
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5, Father shall not permit the child to have contact with Maternal
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 of this 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:4Adams, Esquire, counsel for Father
~arol J. Lindsay, Esquire, counsel for Mother
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NOV 0 8 2005
AMANDA LYNN NICOLE STATLER, : IN THE COURT OF COMMON PLEA
Plaintiff /Respondent : CUMBERLAND COUNTY, PENNSYL
V.
: No. 2001-5833 CIVIL TERM
ROBERT BISHOP PROVINS,
Defendant/Petitioner
: 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 TlERM
AMANDA LYNN NICOLE STATLER, : CIVIL ACTION - LAW
Defendant
: 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:
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 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 L. 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,
/I-?-o{'
Date
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 Grandparentfi.
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Jacq 'i ine M. Verney, Esquire'
Cust 8y Conciliator
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AMANDA LYNN NICOLE STATLER,
Plaintiff /Respondent
I
I
: IN THE COURT OF COMMON PLEAS dF,~ ," '
: CUMBERLAND COUNTY, PENNSYLVANIA
FEB (} ,9 2006
<{
V.
: No. 2001-5833 CIVIL TERM
ROBERT BISHOP PROVINS,
DefendantIPetitioner
: 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,
A'(/~
tody Conciliator
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