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ALM GL ch. 209A, § 10<br />

Page 70<br />

Construct. 26 Harv Women's LJ 217.<br />

Lininger, A Better Way to Disarm Batterers. 54 Hastings LJ 525 (March, 2003).<br />

Long, Commonwealth v. Gonsalves: Erroneously Expanding the Concept <strong>of</strong> Police Interrogation Set Forth in<br />

Crawford v. Washington to Include Investigatory Police Interrogations. 33 N.E. J. on Crim. & Civ. Con. 171 (Winter,<br />

2007).<br />

Buel and Drew, Do Ask and Do Tell: Rethinking the Lawyer's Duty to Warn in Domestic Violence Cases. 75 U.<br />

Cin. L. Rev. 447 (Winter, 2006).<br />

Web References<br />

ABA Domestic Violence Section, see www.abanet.org/domviol/home.html<br />

ABA Family Law Section, see www.abanet.org/family/home.html<br />

Department <strong>of</strong> Social Services, see www.state.ma.us/dss/<br />

Legal Information Institute's Divorce Law Overview, see www.law.cornell.edu/topics/divorce.html<br />

Legal Information Institute's Marriage Law Overview, see www.law.cornell.edu/topics/marriage.html<br />

Probate and Family Court, see www.state.ma.us/courts/courtsandjudges/courts/probateandfamilycourt/<br />

CASE NOTES<br />

Trial court's award <strong>of</strong> legal and primary physical custody to a mother, pursuant to ALM GL c 209C, § 10(a), was<br />

proper where the substance <strong>of</strong> the trial court's opinion indicated that the judge applied the "best interests <strong>of</strong> the child"<br />

standard and also considered the three required factors <strong>of</strong> ALM GL c 209C, § 10(a) in making its custody determination;<br />

the court found that both parents had a close personal and parental relationship with their daughter, it considered where<br />

and with whom the child resided for the six months prior to the initiation <strong>of</strong> the proceeding, and it attempted to preserve<br />

"to the extent possible" the relationship between the child and the primary caregiver. Custody <strong>of</strong> Kali (2003) 439 Mass<br />

834, 792 NE2d 635, 2003 Mass LEXIS 574.

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