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Because women, much more than men, are preeminently interested in custody, seemingly gender-neutral custody rules actually serve to expose women to extortionate bargaining at the hands of their husbands. Jordan, Pa. This gap seems to be widening.

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Since then the Supreme Court of Minnesota, citing Garska, adopted a primary caretaker parent presumption for custody of young children. The law does not attend to traditional concepts of immorality in the abstract, but only to whether the child is a party to, or is influenced by, such behavior.

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