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As Halle Berry’s custody battle with baby daddy Gabriel Aubry plays out in the media, we all know when it comes to celebrities, they don’t always play fair. Halle and Gabriel are battling in court over custody of their 4-year-old daughter, Nahla, as the actress is seeking to move her little girl with her to Paris out of concerns for their safety.

Halle & her baby daddy are not the first to have their battle displayed across our television and computer screens. Take a look at some of the messiest custody battles in Hollywood that offer lessons in how not to behave:


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