confusion of the issues, the witness' safety, or interrogation that is repetitive or only marginally relevant.” Delaware v. Van Arsdall, 475 U.S. 673, 679, 106 S.Ct. 1431, 89 L.Ed.2d 674 (1986) (reviewing a challenge based on the Confrontation Clause). In protection from abuse cases involving self-represented parties, the cross-examination of one party directly and personally by the other may perpetuate or allow intimidation or harassment, or may compromise a party's safety. In such circumstances, a court must provide the opportunity to rebut or challenge the other party’s evidence, but it may take reasonable measures to keep parties safe and prevent intimidation or harassment. See id.; M.R. Evid. 611(a)(3); see also In re Adoption of J.S.P.L., 532 N.W.2d 653, 662-63 (N.D.1995) (<HOLDING>); In re B.G., 225 Ga.App. 492, 484 S.E.2d 293,
holding that the right to crossexamine adverse witnesses applies to capital sentencing hearings holding failure to give putative father notice of adoption proceedings did not violate due process where he had never established a substantial relationship with his child holding that where father who killed his wife had relinquished his children for adoption prior to his conviction the maternal grandparents of the children who had legal custody at the time of the adoption had standing to petition to unseal the adoption records this court vacated the orphans courts order that held the grandparents lacked standing and directed that on remand the orphans court determine whether the grandparents had shown cause under section 2905a to unseal the records holding that a father convicted of murdering his wife in front of their children had no due process right to personally crossexamine witnesses in the childrens adoption hearing holding no right to crossexamine in grand jury proceedings