Kim Basinger went to court as part of a bitter child custody dispute with her ex-husband Alec Baldwin that saw him lash out at his 11-year-old daughter last month on a leaked voicemail.
Superior Court Commissioner Maren Nelson closed the hearing to the public and media minutes after it began, noting that coverage of the protracted dispute had been "emotionally traumatic" for the girl.
"This is only about the well-being of the child and nothing else," Nelson said.
Baldwin did not attend the hearing. He was represented by his attorney Vicki Greene. About a dozen people from a parental rights group stood outside holding signs in support of Baldwin.
Basinger appeared with her attorney Neal Hersh. She wore black-rimmed glasses, a gray jacket and black blouse.
Another attorney represented their daughter, Ireland.
The couple divorced in 2002.
Baldwin has spent the past few weeks trying to explain why he lashed out.
He issued an apology on his Web site, sat down with TV talk show hosts Barbara Walters and Rosie O'Donnell and asked NBC to let him out of his "30 Rock" contract to devote time to the issue of "parental alienation."
In his message, Baldwin, 49, can be heard berating his daughter as a "rude, thoughtless little pig" for missing his call. A tape of the message was obtained by celebrity Web site TMZ.com and broadcast worldwide.
The actor blamed his former wife for leaking the tape, which she denied. He also suggested his comments were meant for Basinger, 53, not their daughter.
A separate hearing is scheduled for June 5 about the leaked tape.
Greene said in a court filing that its public disclosure violated a court order to keep the proceedings confidential.
The tape is only the latest issue in the custody dispute.
In October, Nelson denied a motion by Basinger's attorney to dismiss 12 misdemeanor counts of contempt against the actress. Basinger, who has pleaded not guilty, is accused of failing to heed court orders in the case.
She faces up to 60 days in jail and a $12,000 (EUR8,850) fine if convicted of all counts.
In November 2005, Baldwin and Basinger traded accusations of emotional instability as they argued over their rights to telephone and e-mail time with their daughter.