Rowe gave up parental rights to Jackson in 2001, but she changed her mind more than two years later and sought temporary custody of the children.

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The owner of a janitor service, Dalrymple visited the Miami relatives of the boy daily when Elian was in the temporary custody of his great-uncle, Lazaro Gonzalez.

CNN: Elian 'fisherman' files $100 million civil rights suit against Reno, Meissner

The appeal document also seeks to answer ICC concerns about Saif al-Islam Gadhafi's well-being, saying the government "has expended considerable resources in order to ensure the safe and secure temporary custody" of Gadhafi in Zintan and is negotiating to bring him to the capital, where facilities would be better.

CNN: Libya appeals ICC order to hand over Saif Gadhafi