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Home My WebLink About94-03892 ~ .) . ~ :a~ ~ ~-- ,- . ~ oS " ~ ~ l") li) - ~'It: \' .,.~ ~~ II "'J If) \l'\ -::r- 'J '.0 c I.rt 0 . Cl ~~ , -1) ,"-_I .- QE~ -~ &.: [)~ 3 ~I ~I . ~ ~ ~ '" ~I fIJ - i~ a ~~~~~ olS III .., IE >< ffi~ ~ ot II m o Ol!GlIoE ~~~~~~ ~ ~~ IIH , ~ > t.:lp.~~o ~ .. i!'l ~:t fIJ p. ~ u ~ ::l ~ U fIJ .. . I ". f.. . " . , ., '';If rP~t1 ~ . . MITCHELL ANTHONY ROWI.ES, I by KATHRYN ROWLES, I Pursuant to Special I Power of Attorney, I Plaintiff I v. I I LIJIA JULIESE ROWLES, I Defendant IN 'l'HE COUIl'I' 01" COMMON PLEAS OF CUMnERLAND COUNTY, PENNSYLVANIA 94- :3 '6 '1,~ CIVIL TERM CIVIL ACTION - CUSTODY ORDER AND NOW, this ~ day of )J.k\ , , 1994, upon consideration of Plaintiffs' Petition for Special Relief, IT IS ORDERED AND DIRECTED that temporary physical custody of Kayla Igrayne Rowles, D,O.B. 1-29-91 and Mariah Ilayne Rowles, D.O.B. 5-17-93 is placed with Kathryn Rowles pending further Order of Court. Further, Defendant Lijia Juliese Rowles is enjoined from vania~ct,~ removing the children from the Commonwealth-Of Penn c..... ~ v, "" '\ o....l- BY T I 0 'N v1- oIk, '\ ~,;)ci..l'.u., Lv.it, \. "', 1 q (?t!Jt I -to tk ~ \4l\ , Nt t (.: ~ ~-vtt'~ (9vclJL, /)jJ~J2 ~~ .Nt.... Q.~ LJ \t\ t, \ (^ AJh>'O I V ~ -0 vV~ eN"' tvu. VV\!J-1 t b l\l J. c1 (I.(/y ht.L{~M;,A- \ ; ,V1) h/) ""' JUl /2 3 WI il/ '9~ :,j ; f'-~i~ ",:',\---:r1~l liT " J __-~ :' ft MITCHELL ANTHONY ROWLES, by KATHRYN ROWLES, Pursuant to special Power of Attorney, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 94- j~'1'l. CIVIL TERM CIVIL ACTION - CUSTODY LIJIA JULIESE ROWLES, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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. Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240 \00 l'~ 1 W lliam c. Vohs, Esquire SAlOIS, GUIDO, SHUFF & MABLAND 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for the Plaintiff SAIIlIS, GUillOt SIIUI1I1 & MASI.ANU u, W IlIgh SIr<<l Cnrlhlc,l'A II 'I I, il ii I, Ii MITCHELL ANTHONY ROWLES, : ii j'i,: by KATHRYN ROWLES, . Pursuant to Special d Power of Attorney, !1 Plaintiff !I " !i I ,I Ii Ii I' II d Ii 11 II I , I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94- 38'1J CIVIL TERM v. CIVIL ACTION - CUSTODY LIJIA JULIESE ROWLES, Defendant PETITION FOR SPECIAL RELIEF COMPLAINT FOR CUSTODY 1. The Plaintiff is Mitahell Anthony, residing at Engineering Department E. Division, USS Belleau Wood LHA-3, PFO ! AP96623-16l0, United States Navy. The Plaintiff Kathryn i , ~ Rowles, is Mitchell Anthony Rowles' mother and has Special ~ Power of Attorney executed on June 27, 1994, residing at 339 !I Ii Garland Avenue, Carlisle, Cumberland County, Pennsylvania ii 17013, a copy of said Special Power of Attorney is attached " ~ hereto and made a part hereof marked as Exhibit "A". :! \ 2. The Defendant is Lijia Juliese Rowles, residing at 339 Ii :i l Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. ~ 3. Plaintiff seeks custody of the following children: , Name Present Residence ~ Kayla Igrayne Rowles 339 Garland Drive 2 1/2 Carlisle, PA 17013 Mariah Uayne Rowles 339 Garland Drive 1 Carlisle, PA 17013 The children were not born out of wedlock. The children are presently in the custody of Plaintiff Kathryn Rowles and Defendant, who reside at 339 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. The children have resided with the following persons and Ii I, at the following addresses: Ii Ii I: ,j U Mitchell Anthony Rowles & Norfolk, Virginia Ii Lijia Juliese Rowles 'I ~ Mitchall Anthony Rowles & portsmith, Virginia Ii Lijia Juliese Rowles ~ Mitchell Anthony Rowles & Paradise Hills, CA II Lijia Juliese Rowles " ~ Mitchell Anthony Rowles & Japan I' Lijia Juliese Rowles 'I :, Ii Kathryn Rowles & il Lijia Juliese Rowles ii Ii II ~ Rowles, currently residing at 339 Garland Drive, Carlisle, II ~ Cumberland County, Pennsylvania 17013. j1 II I: I ~ Rowles, residing at Engineering Department E. Division, USS ,I it ~ Belleau Wood LHA-3, FPO AP96623-1610, through Special Power of Persons Addresses Dates Not Availbble Not Available 9 Months 1 1/2 Yrs. 339 Garland Drive Carlisle, PA 17013 June 10, 1994 to Present The mother of the children is the Defendant Lijia Juliese She is married. The father of the child is Plaintiff Mitchell Anthony r " Ii Attorney, the paternal grandmother Kathryn Rowles resides at ,I ~ 339 Garland Drive, Carlisle, Cumberland County, Pennsylvania Ii 17013. He is married. 4. The relationship of Plaintiff Mitchell Anthony Rowles SAIllIS,ClUIDO, to the children is that of father. The Plaintiff currently slIun' & MASLANU resides with the following persons: 26 W IlIg" SlI<<1 l'wll>le,I'A ~ Relationshil;! Between 4000 and 6000 None various servicemen aboard an aircraft carrier, currently at sea at an unknown location on the Pacific Ocean 5. The relationship of Plaintiff Katherine Rowles to the children is that of paternal grandmother. The Plaintiff Kathryn Rowles currently resides with the following persons: Relationship ! ~ I i Lijia Juliese Rowles ~ Kayla Igrayne Rowles , ~ Mariah Ilayne Rowlss I: !, John A. Rowles II Daughter-in-Law Granddaughter Granddaughter Husband 6. Plaintiff has not participated as a part or witness, Ii I, II ~ or in another capacity, on other litigation concorning the Ii Ii I Ii " I' Ii I' I: 'I I, Ii ,I custody of the children in this or another court. The court, term and number, and its relationship to this action is: Not applicable. Plaintiff has no information of a custody proceeding ~ concerning the children pending in a court of this " 'I 11 I, iI il Ji Ii Ii !i !! Commonwealth. The court, term and number, and its relationship to this action is: Not applicable. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims , I to have custody or visitation rights with respect to the children. The name and address of such person is: Not SAIllIS, GUmOt applicable. SIIUI1I1 & MASLANU 7. The best interest and permanent welfare of the 2(, w, lIigh Slre<1 l'B1Ii1I<,I'A children will be served by granting the relief requested because the children have lived with their father all'of their natural lives, except for his times at sea; the children have lived with Plaintiff Katherine Rowles since June 1994; SAlOIS, GUIllO, SIIUFI1 & MASLANU 26 W, '"gh SIr<d CAI'lhlc,I'A I ,; I I I II II I I Defendant suffers from psychological and emotional problems I I 'I , which render her unfit; the Defendant has threatened to remove the children from this Court's jurisdiction and take them to the State of New York on July 12, 1994. B. Each parent whose parental rights to the child have ! i ~ not been terminated and the person who has physical custody of I I I I Ii Ii 'I Ii Ii " Ii ! i the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene I None. WHEREFORE, Plaintiff requests this court to grant custody i j of the children to the father through the paternal ~ grandmother's special Power of Attorney. .1 !i II II 1:1' I incorporated herein as if set out completely. j 10. Plaintiff Kathryn Rowles and Defendant engaged a II ~ verbal confrontation today, July 12, 1994, which required the Ii ~ assistance of the Carlisle Police Department to resolve. j! ii ~ 11. During that confrontation, Defendant informed " SPECIAL RELIEF 9. The averments contained in paragraphs 1 through 8 are Plaintiff that Defendant intends to move to New York State this evening, taking the children. 12. Defendant is unemployed and currently has no resources to provide for the children. 13. Plaintiff Kathryn Rowles, has provided for all the children's needs since June 10, 1994. 14. plaintiff Kathryn Rowles has also been Defendants sole SAlOIS, GUillOt SIIUFlI & MASLANU 26 W, IIlah Slreel Cullile,I'A . . '. VERIFICATION I verify that the statements made in this complaint and Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated:..... kJPy /J,. {11LI SPEcr TlL iJOWEH OF' TlTTORNEY KNOW TlI.[, MEN rw TIlESI': I'RESFN'l'S: That I, Mitchell 1\, Howleu, il le~.ll reuident of Pennsylvania, United Stateu of TlIII<:dca, Social Security Number 191-4G-1137t presently on active dllty in the United States Navy, do hereby make, constitute, and appoint John A. Rowles, who rea ides at 339 Garland Drive Carlisle Pennsylvania, 17013, my true and lawful attorney for me and in my name, place, and stead to: To take tl~mpcTary clIlltody, prov ide support and educat ion of lilY children: ~ Kayla Igrayne RowltH! Mariah Ilayne Rowles Mill 02 01 QQJl 29 Jan 91 18 May 93 ilnn ::If: 01w~'di;\1! r)f I-II'~ pi)I','rlfl 'If 11" I"h; J., 't":':1' t!l n0 any ann ::tl] acts in tll'!ii" disL'~er.lo'l, wlliclI lIlc.}' c,,<:: c.l.;t!UI"'-! IleCebl:ld1j for the support, care, comfort, education and health of my child(ren) . Such acts shall include but are not limited to tests, to r"equesting and consenting to dental and surgical diagnosis or treatment, including hospitalization, disciplining the above named child(ren), enrolling the above named child(ren) in school, and to consent to the employment of the above named child(ren) , I hereby authorize the guardian of the person of my child(ren), to enter any military installation for the purposes of utilizing military medical, exchange, and commissary privileges according to the 1"wful entidelllents of my dependent child(ren), Includ'ld ill thl! forl~(.ning i8 the apecific power to file, on behalf of my dependent chil,l(renl, any and all claims for reimbursement for medical services received by my child(ren) from private health care practit ioner-s covered under the CHAMPUS Program. Hereby giving and granting unto my said attorney full power and authority to do and perform all and every act and thing whatsoever requisite and necessary to be done in the premise, as fully, to all intents .1nd purposes, as I might 01' could do if persona 11y present, 1\." (~h,! .'1t i fyinq nnd conE irlni n9 all that: my said att.orney sll,lll l;;;v'ully do h" CdlltJe to be dune by virtue hereof. Tlnd 1 hereby declare Lh<ll allY act or thing lawfully done her"eunder by my said iitt0r"0"'1'" in- fact shall be binding on myself, and my heirs, legal and persunal IP!Jl-esent:atives, and assigns whether the same shall hav,' been d;Jlll~ befol"e or after my death, 01- other revocations of. tllil' innl nlln._'nl:, unless and until reliable intelligence 01 nUllr:" I"hen~ot shall have been received by my said attonley"in-[acl; ,'Ind wh.~t1,PI 01" not I, the grantor of this instl"ument, shall hdve bc'~n Jepel"Led or listed, either officially or othl'Jwiue, .Ifl "lIIiuning,in-act.!on" au that phraBe is \HIed in naval pal"".IIlce. il: beinrl the intendmenl: hereof that Bueh fJLal:\lS designat lell :111.111 liut bilr my attonit.y- in- fact h"om fully ilnd cumpletrdy ",;I.,l"r'illinq ,Ind cunl illuin,! to l'x"n:ifJ(! ilny olnd <II] I'OW,-j"U and riqhl f; 1I"ll'in III .lnl ,';1, and that Bueh u'port of. "l1linnillq-ill-iH'LlIJII" 1111.:111 1l1,.itill71 clJllul.itlltl_' or be illt.'I"JH'.~I.pd dll L'UlluLitlllill<J 1\,11 i"I' ld :1\'" dt'i1LI1 III t Il}1t'l'dl'> II) rj'vIJk,~ t.hi!; inntl'llm('nl . I further rieda!'e that lIolIJlI:hul'itllclillg lilY insertion of a specific expirati(IJ1 date I1I)1'-dl', if: IIn the below specific expiration date, ai' if a', ,Ill\, t' il\ll~ Wltlil:l l:Ili rty days immediately preceding that opel.: if i': 1'~:!'l1'..;I' 1,:," dnl e, J !lhould be or have been, carried in il -nili l al')' 'Jt.ll.'"'' '-,i "I,1i f3sil1<]- ill-action," "missing," or "pl'illOneL at: Well'," thell thio pt)~ler of attol"lley shall automatically conti~ue to remail1 valid and in full effect until sixty days after I howe retul'ned to United states military control following termination of such "misoing-in-action," "missing," or "prisoner-of-war" status. ji I , This Special Powel' of Attorney shall commence on the date of signature hereon and exp!re 011 2"l:h June 1995. IN WITNESS WHEREOF', I I.IiV'" h..reulltu !let my 'land a.ld Ileal this 27th June 1994. 11J&"/LJ~~ f.tHl;CJf.., 1\. ~it:l' ACKNOWLEDGEMENT WITH THE UNITED STATES ARMED FORCES AT SASEBO, JAPAN I, cynthia A. Fout, the undersigned petti' officer, do hereby certify that 011 this 27th June 19%, before me personally appeared Mitchell A. RovI1FlS. who hae proved to me on the basis of satiofactory e\'ic.il:'nce 1;1) bf.o tile ideutlcal person whe is described ill, whose name is aubscdberl to, imil who acknowledged to me that hl~/she signed and seillp.d Lh~ Iliill\~, ora ::he date it bears, as hia/her trlJe, trut!, ar:d V(JlLl'II,iit'~1 <iC': 11l1d rl~,~d, for. lJses, purpoaell l1nd CI)l1nlderatiollfl .:herp;n Il'!'; tr~rth r,nd 1 uo further certify th.Jt I ar,' at the 'illl.'~ oi thif.i r.er'tiflcate a petty officer of the grade, branch of &urvice and organization stated below in the active service of the Unit~d State~ ~rmed Forces, and that this certificate is executed in my capacity as it petty officer under statutory authority grant~d to me by Article 136, Uniform Code of Military Justice (10 USC 936, 10 USC 1044a) and the Manual of the Judge Advocate General (JAfJMAN), Sections 0902 and 090~. as a NotalY Publio:' nnd Consul col' thE' United StateR, and thill' by statute!, 110 flei.l io req1Ji~:t~d Jr, :-hia certificate. ,I " ~4 //'// .__,_ ~ ./'-J4/. C}' I' lia A. Fout Legalman First ClaDR, USN AlI'l'H, 10 USC 1044a MITCHELL ANTHONY ROWLES, by KATHRYN ROWLES, Pursuant to special Power of Attorney, plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-3892 CIVIL TERM LIJIA JULISSA ROWLES, Defendant CUSTODY dCUaySTOoDfY ORO~ t1~ AND NOW, this ~ ~~ ' 1994, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children Kayla Igrayne Rowles, born January 29, 1992, and Mariah Ilayne Rowles, born May 18, 1993. 1. The defendant, Lijia Rowles, hereinafter referred to as the mother, and the plaintiff, Mitchell Rowles, hereinafter referred to as the father, will share legal custody of the children. 2. The mother will have primary physical custody of the children. 3. The father will have partial physical custody of the children every other weekend from Friday at 6:00 p.m. to Sunday at 6:00 p.m., and every Tuesday from 6:00 p.m. to 8100 p.m. 4. For the duration of the special Power of Attorney, the paternal grandparents will exercise the father's partial physical custody rights. 5. The father and mother will alternate Christmas Eve and Christmas Day each year, one parent having the children from Christmas Eve at noon until Christmas Day at noon, and the other parent having ths children from Christmas Day at noon until December 26 at noon. 6. The parties will alternate the following holidays: New Year's Day, President's Day, Easter, Memorial Day, the Fourth of July, Labor Day, and Thanksgiving. In 1994, the mother will have the children on Labor Day. The holiday schedule supercedes the regular weekend schedule, and when a holiday is celebrated on Monday, the party having custody for the holiday will have the children from Friday at 6:00 p.m. until Monday at 8:00 p.m. If this interrupts the regular weekend rotation, the party losing a weekend will have custody of the children for the two weekends following the holiday. 7. The mother will have the children on Mother's Day, and the father will have the children on Father's Day. 8. The father will have the right to partial custody of the children for two non-consecutive weeks each year. The father will give the mother thirty days notice as to when his period of week long custody will take place. The mother also has the right to take the children on a vacation including a maximum of two weeks and three weekends. 9. The mother and father, by mutual agreement, may vary from this schedule at any time. 10. The mother and father will notifY each other of all medical care the children receive while in that parent's care. Each parent will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 11. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children' other parent. } JUL 20 IZ 30 fH '9~ j,. TI]it11.l lict iI,'I~'",'1A~V (,,;,..rHI 1,"0 W'I.HilY I f'1I11'\.\'PI1t --..- MITCHELL ANTHONY ROWLES, by KATHRYN ROWLES, Pursuant to Special Power of Attorney, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-3892 CIVIL TERM LIJIA JULISSA ROWLES, Defendant CUSTODY CONSENT AGREEMENT This Agreement is entered on this \~~ 1994, by Kathryn Rowles pursuant to a Special day of .~\.. o Power of Attorney on behalf of the plaintiff, Mitchell Anthony ROWles, and the defendant, Lijia Julissa Rowles. The plaintiff is represented by William C. Vohs of saidis, Guido, Shuff & Masland; the defendant is represented by Joan Carey of Legal Services, Inc. 1. The defendant, hereinafter referred to as the mother, and the plaintiff, hereinafter referred to as the father, agree to the entry of an Order providing for the following custody schedule for their children Kayla Igrayne Rowles and Mariah Uayne Rowles: a. The mother and the father will share legal custody of the children. b. The mother will have primary physical custody of the children. c. The father will have partial physical custody of the children every other weekend from Friday at 6:00 p.m. to sunday at 6:00 p.m., and every Tuesday from 6:00 p.m. to 8100 p.m. d. For the duration of the special Power of Attorney, the paternal grandparents will exercise the father's partial physical custody rights. e. The father and mother will alternate Christmas ~ve and Christmas Day each year, one parent having the children on Christmas Eve at noon until Christmas Day at noon, and the other parent having the children from Christmas Day at noon until December 26 at noon. f. The parties will alternate the following holidaysl New Year's Day, President's Day, Easter, Memorial Day, the Fourth of July, Labor Day, and Thanksgiving. In 1994, the mother will have the children on Labor Day. The holiday schedule supercedes the regular weekend schedule, and when a holiday is celebrated on Monday, the party having custody for the holiday will have the children from Friday at 6100 p.m. until Monday at 8:00 p.m. If this interrupts the regular weekend rotation, the party losing a weekend will have custody of the children for the two weekends following the holiday. g. The mother will have the children on Mother's Day, and the father will have the children on Father's Day. h. The father will have the right to partial custody of the children for two non-consecutive weeks each year. The father will give the mother thirty days notice as to when his period of week long custody will take place. The mother also has the right to take the children on a vacation including a maximum of two weeks and throe weekends. 2. The mother and father, by mutual agreement, may vary from this schedule at any time. 3. The mother and father will notify each other of all medical care the children receive while in that parent's care. Each parent will notifY the other immediately of medical emergencies which arise while the children are in that parent's care. 4. The parties realize that their children's well being is paramount to any differences they might have between themselves. Therefore, they agree that neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children'S love or respect for the other parent. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. / ,'} ~~ kL/' 17'- '" a~l'., / Michael nthony Rowles, by Kathryn Rowles, Pursuant ;0 a iec / Power of atto"e" 7J oan Carey Attorney fo Defendant LEGAL SERVICES, INC. a Irvine Row Carlisle, Pa 17013 (717) 243-9400 1 am C. Vohs Attorney for Plaintiff SAIDIS, GUIDO, SHUFF & MASLAND 26 West High Street Carlisle, PA 17013 (717) 243-6222 ~ z o ~ ~ t .~ 1 i Sf I' 27 zuuuf1? MITCIIELL ANTIIONY ROWLES, Plalntifl' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA vs. : CIVIL ACTION. LA W : NO, 94.3892 CIVIL TERM L1JIA JULlSSA (ROWLES) BERT. Dcfcndant : IN CUSTODY ORDER OF cOVIn AND NOW, this 2R day of ~. 2000 it is decrecd that the Stipulation and Agreement for Custody and Partial Custody that has bccn executed by the parties named above shall be made an Ordcr of this Court. Thc Court of C0l11111on Picas of Cumberland County shall maintain jurisdiction in this mailer. BY THE COURT. '" , L1jia Jullssa (Rowles) Bert. pro Sf! . ~ ~1.jJ'OO ~G cc: James J. Kayert Esquire Allomcy for Plaintiff '.. In h' ~ j:: c ". ". ," ('.~ ",,'- , .' / .J , ... ". ,I :. , u. , ~:~ ~ ,.J , , :1 . r:-j , ~."J I - C_ o ~.. l. o ;'i:j "1 t..h;.. ." \,,1 r., :-.i <":1 (J UGL'[l'2ILILI I' H1L I I'd '''i~IIW:) . illlll,I^V ^l""i'l 3 I' . lIul ^Imqll lJOIII'JUdlO:) il'lluls~OIOJd V , ' UMOJB pue Ja,';e>t ., .. .. :> c Iii r'I (:0>0 :s "" <{ t-. e ~ it'- ~ UI 8::J ~ 'tJ-uJ ~ C ~ '<t '" III ,2 . Iii ~ 5lii~:::Q..E -- .s" ~ ~~ <{ .88 ::J ullcnlllting cyclc, 5, Fathcr shall havc physicul custody of the minor children on Fathcr's Day, Mother shall have physicul custody ofthc minor children \11I Mother's Day, 6. The parties shall share physicul custody of thc minor children on each Christmas and birthduy, 7. Neither party shall remove the ehildren from the Conllltonweallh ofPennsylvunia without providing the other purty prior wrillennotice or verlllll notice of their intention at least fourteen (14) days in advunce, 8. The parties shall mutually be responsible Illr transportation arrangements to and from each of their periods of physical custody with the children, 9. The parties agree and anticipate that this agreement for eustody and visitation may be entered us un Order of Court in the Court of Common l'leas of Cumberland County, Pennsylvania. 10, The parties do hereby stipulate and agree that they waive their respeetive rights to be present in court at the time an order is made pursuant 10 this Agreemenl for Custody and Visitation. IN WITNESS WIIEREOFt the parties hereto and each ofthem have hcreunto set their hands c' ;;)OO2:l and seals intending to be legally bound hereby this _J~::tl~ day of~...ll\ \'\0 _\ ,tt)98': Lle-H~~/' MITCIIELL ANTHONY ROWLES , . . ~tWI ( ~J.d~~t L1J1A ULlS. A OWLES BER