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Footnotes
1. It has also been argued that Article 8 of the ECHR also gives parents a right of contact to their child but the European Court has denied that grandparents should have an automatic right of contact. (Bainham 2003: p. 65).
2. Lehner, L.1992 "Mediation Parent Education Programs in the California Family Courts" Family and Conciliation Courts Review. Vol. 30, No. 2, April.
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