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Conditional probability
Paul Meagher gives an example of calculating conditional probability using the set enumeration method.

Understanding Bayes Using PHP
Paul Meagher introduces Bayesian inference by discussing the basic mathematical concepts and demonstrating how to implement the underlying conditional probability calculations using PHP.

Transparen Corporation Canada Day Celebrations July 1, 2006
Transparen Corp. is proud of its Canadian heritage, and gladly celebrates Canada Day every year. Look back at previous Canada Days to learn about Transparen's history.

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Linux Email Virus Protection
Transparen Corp. supports ClamAV, a GPL command-line virus scanner. Nevertheless, avoid opening attachments from strangers...

Support for Mozilla and Firefox
Transparen Corporation provides technical support for companies migrating from Internet Explorer to Mozilla or Firefox.

Arizona Child Custody -- Arizona Family Law Attorneys
Arizona Child Custody cases are governed by ARS Section 25-403 - "Custody; best interests of child".A. The court shall determine custody, either originally or on petition for modification, in accordance with the best interests of the child. The court shall consider all relevant factors, including: 1. The wishes of the child's parent or parents as to custody;2. The wishes of the child as to the custodian; 3. The interaction and interrelationship of the child with the child's parent or parents, the child's siblings and any other person who may significantly affect the child's best interest; 4. The child's adjustment to home, school and community; 5. The mental and physical health of all individuals involved; 6. Which parent is more likely to allow the child frequent and meaningful continuing contact with the other parent; 7. Whether one parent, both parents or neither parent has provided primary care of the child; 8. The nature and extent of coercion or duress used by a parent in obtaining an agreement regarding custody; 9. Whether a parent has complied with chapter 3, article 5 of this title.10. Whether either parent was convicted of an act of false reporting of child abuse or neglect under section 13-2907.02.B. In a contested custody case, the court shall make specific findings on the record about all relevant factors and the reasons for which the decision is in the best interests of the child.

California Ban on Same-Sex Marriage Struck Down
In a much-anticipated 4-3 ruling issued Thursday, the California Supreme Court struck down the state's ban on same-sex marriage as unconstitutional Gay couple John Lewis, left, and Stuart Gaffney celebrate outside the California Supreme Court on Thursday. The ruling clears the way for the state to become the second to legalize same-sex marriage.Several gay and lesbian couples -- along with the city of San Francisco and gay rights groups -- had sued, saying they were victims of unlawful discrimination. A lower court ruled San Francisco acted unlawfully in issuing marriage licenses to same-sex couples, but Thursday's ruling overturned that decision.

Star Jones Files For Divorce
NEW YORK (AP) -- Three years after tying the knot in a spectacular, over-the-top affair that caused some backlash, Star Jones has decided to end her marriage to banker Al Reynolds.Star Jones and Al Reynolds, here in 2006, married in late 2004.The 46-year-old TV personality quietly filed divorce papers March 26 in New York Supreme Court in Manhattan. The records are sealed, syndicated entertainment show "Entertainment Tonight" reported Wednesday. For more information on Arizona Divorce Lawyers, contact NRG.But a representative for SHADOW PR, which represents Jones, confirmed to The Associated Press that she is seeking to end the union.In a statement to "Entertainment Tonight," Jones said: "Several years ago I made an error in judgment by inviting the media into the most intimate area of my life. A month ago I filed for divorce."The dissolution of a marriage is a difficult time in anyone's life that requires privacy with one's thoughts. I have committed myself to handling this situation with dignity and grace and look forward to emerging from this period as a stronger and wiser woman."It's not the approach Jones took when she threw her uber-lavish, Park Avenue wedding to Reynolds in November 2004. She received criticism for endlessly discussing the wedding -- and plugging its sponsors -- as a co-host on ABC's "The View." The negative reaction to the affair, which was attended by guests ranging from Sen. Hillary Rodham Clinton to Spike Lee, was cited by Barbara Walters as a reason why Jones' contract wasn't renewed by ABC's "The View" in 2006.The former prosecutor recently hosted a talk show on truTV

The Art & Science of Custody Evaluations
If you are interested in learning more about custody evaluations, check out this book.If you need to see a Arizona custody lawyer, contact www.nrglaw.net for a complete analysis of your situation.

Ex-Wife of Former Beatle Explains Dousing of Opposing Counsel
LONDON, England (AP) -- The ex-wife of former Beatle Sir Paul McCartney said Friday that she snapped when she poured a jug of water over the head of her former husband's lawyer during their bitter divorce battle in Britain's courts.McCartney's lawyer Fiona Shackleton, left, pictured after Mills threw water over her.Heather Mills said she became angry when McCartney's lawyer Fiona Shackleton argued that full details of the case, including some related to their daughter, should be disclosed."Mrs. Shackleton said something under her breath so I cleansed and baptized her," Mills told Britain's GMTV on Friday. "I thought she looked fantastic -- I thought it did her the world of good."Mills was awarded a $48.6 million divorce settlement last month after her four-year marriage to the former Beatle.But judge Hugh Bennett said Mills was a less than candid court witness whose original demand for $250 million was exorbitant.Mills' evidence was "not just inconsistent and inaccurate but also less than candid. Overall she was a less than impressive witness," Bennett said in his judgment.Mills was speaking from Las Vegas, where she is among celebrity judges for the Miss USA pageant. Mills joins actor-comedian Rob Schneider, actor-musician Joey Fatone, Olympic champion swimmer Amanda Beard and others on the panel.

Wife of Entertainment Mogul Simmons Files for Divorce
LOS ANGELES, California (AP) -- Kimora Lee Simmons has already moved on, but she took steps to make it official by filing for divorce from her husband of seven years, entertainment mogul Russell Simmons.For information on Arizona divorce law, see NRG Family Law.Kimora Lee Simmons and Russell Simmons have been married for seven yearsAlthough the couple separated in March 2006, Kimora Lee Simmons just filed divorce papers Tuesday in Los Angeles Superior Court. The 32-year-old Baby Phat fashion designer and reality TV star cited irreconcilable differences.She and Russell Simmons, 50, have two daughters: 8-year-old Ming Lee and 5-year-old Aoki Lee.

Christina Applegate Divorce Finalized
LOS ANGELES, California (AP) -- Christina Applegate is now unmarried ... with no children.Johnathon Schaech and Christina Applegate were married in 2001. The actress and her actor husband, Johnathon Schaech, have officially parted ways a year and a half after he filed for divorce. The pair's split was finalized in Superior Court on Friday, according to court documents obtained by CelebTV.com.Applegate, known for her role as ditzy daughter Kelly Bundy on TV's "Married ... With Children," and actor Schaech married in October 2001. They separated in November 2005, citing irreconcilable differences, according to court papers. Schaech filed for divorce December 5, 2006. Applegate's publicist, Ame Van Iden, and Schaech's publicist, Cindy Guagenti, both declined to comment Friday.The judgment awarded Schaech more than $1.5 million in bank accounts dating back to last February, a cement Buddha in Applegate's possession, and a 2001 Mercedes-Benz S500.Applegate, 35, was awarded two of the ex-couple's Los Angeles residences, a 2006 Lexus and more than $7.5 million in bank accounts dating back to late December 2006, according to court documents.Applegate has starred in movies including "Anchorman: The Legend of Ron Burgundy," and earned a 2005 Tony Award nomination for her Broadway role in "Sweet Charity." Schaech's acting credits include 1996's "That Thing You Do!" and 2005's "Sea of Dreams."Both waived the right to seek spousal support.The pair did not have children.

Asylum Ruling Leaves Out Chinese Spouses
(AP) - NEW YORK-The husbands of women forced to abort a pregnancy or undergo involuntary sterilization, or else face persecution under China's coercive population control program, do not automatically qualify for asylum, a federal appeals court ruled Monday.The ruling by the 2nd U.S. Circuit Court of Appeals found that U.S. law does not automatically grant asylum to spouses or partners in cases in which the women have been persecuted under China's family-planning policy, which limits most urban couples to one child and families in some rural areas to two.The ruling conflicts with a dozen other federal appeals courts, as well as the findings of the the Board of Immigration Appeals and 10 years of decisions in immigration cases, said Judge Guido Calabresi, who partially dissented. The ruling was unusual because all 12 judges joined the opinion.The court said that the board, which decides whether to accept immigration judges' conclusions, had been too permissive and that spouses do not necessarily qualify for asylum.The majority opinion, written by Judge Barrington Parker, said spouses would have to prove their own resistance to a coercive population-control program or demonstrate a well-founded fear that he or she will be subjected to persecution for resisting the policy.However, the judges said the ruling should not result in the reopening of cases in which Chinese refugees have been granted asylum. The opinion also noted that Congress can rewrite the law if it finds the court's interpretation inconsistent with its intentions.The court was ruling on three separate asylum cases, none involving spouses. Two of the cases involved boyfriends of women awarded asylum, and the other involved a fiance.China's family planning policy was implemented in the late 1970s to control population growth and conserve natural resources. Human rights activists claim it has led to forced abortions, sterilizations and a dangerously imbalanced sex ratio because of a traditional preference for male heirs, which has prompted countless families to abort female fetuses.

Federal Court Restricts Pro Per Child Custody and Child Support Litigant From Further Filings & Appeals
In Andrews v. Heaton, a pro per litigant filed three appeals and an array of appellate motions arising from two federal lawsuits he brought seeking to compel federal judges to enjoin state court proceedings and obtain damages from them regarding rulings in child support custody matters. Mr. Andrews's complaints were deemed defective, among other things, for the following reasons: (1) they sought to assert claims against defendants entitled to absolute judicial immunity, (2) failed to meet the heightened pleading requirements of Rule 9(b) of the Federal Rules of Civil Procedure, and (3) sought to enforce criminal statutes through a civil action. To read the full opinion, click here. Contact NRG if you would like advice regarding your child custody or child support case.

Press Release: Arizona Foundation for Women
DOMESTIC VIOLENCE - Although there has been progress over the last two years in funding domestic violence shelters in Arizona, roughly 2/3 of all women seeking shelter are still turned away due to lack of space. Both the Governor and the legislature support an appropriation of least $3 million to increase the number of shelter spaces and help to end turn-aways. $3 million is reportedly included in the Senate draft budget.Domestic Violence WHAT'S GOING ON? Lots going on! $3 million for additional shelter beds seems very likely to be included in the final state budget. More immediately, SB1227, which allows victims of domestic violence to terminate their lease for safety reasons, has passed and is ready to go to the Governor- thanks to all who sent emails! SB1424, which allows for enhanced penalties for repeat domestic violence offenders, has passed, and is headed for the Governor's desk as well. WHY IS IT IMPORTANT TO ARIZONA WOMEN? Both bills will keep victims safer, and send an important message to abusers that Arizona takes domestic violence seriously. WHAT CAN I DO? Contact Sponsors Senator Jim Waring and President Tim Bee. These men are heroes who fought off powerful interest groups in order to get these two bills passed. Thank them for helping SB1227 and SB 1424 go all the way. Jim Waring jwaring@azleg.gov Tim Bee tbee@azleg.gov

Anna Nicole Smith's Baby's Father Identified
Photographer Larry Birkhead is the father of Anna Nicole Smith's baby, a Bahamas court ruled today after seeing DNA evidence. He said: "My baby's gonna be coming home pretty soon." Howard K. Stern, who is named as the father on Dannielynn's birth certificate, said he would not fight the ruling.At NRG, we deal with paternity issues regularly. If you would like to discuss your specific matter in detail with one of our attorneys, please feel free to contact us at www.nrglaw.net.

Voicemail is Discoverable
Messages left on voicemail can be introduced as evidence.Under Rule 34 (a) of the newly adopted amendments to the FRCP Rules, electronically stored information is now described as; "electronically stored information - including writings, drawings, graphs, charts, photographs, sound recordings, images and other data or data compilations stored in any medium from which information can be obtained - translated, if necessary, by the respondent into reasonably useable form, or to inspect, copy, test or sample any designated tangible things which constitute or contain matters within the scope of Rule 26(b).Voicemail as compared to e-mail in electronic discovery has rarely been an item of interest in the majority of production disputes. In discussions with large numbers of attorneys throughout the past few years, when we bring up voice mail messages as discoverable ESI, the majority of litigators are stumped as to why voice mail is not brought up in civil litigation.Government investigators and trial lawyers alike are being trained on the retrieval of electronic data, including digitized voicemail. Odds are they will be able to get it. Digitized voicemail is a discoverable medium because the rules that govern discovery allow parties to request "data compilations." Under these rules, courts have ordered the production of relevant voicemail messages and files and have even required the producing party to identify all back-up files or archival tapes that would provide information about deleted data.Plan to Act NowNow, rather than when faced with a government subpoena or civil discovery request, is the time to plan your response to requests for voicemail records. Responding to these requests will be no small task. Unlike e-mail, voicemail programs typically do not have a built-in search capability. Messages cannot be scanned by the human eye for key words and phrases; each voice message must be listened to in its entirety in real time in order to determine if it contains relevant information. Planning ahead on how to respond to requests will benefit you in several ways.* If you become involved in litigation, you will need to search your own voicemail database for messages to support your case because federal rules require mandatory disclosures of materials that a party intends to use to support its claims and defenses.* A key admission from the other side may come in the form of a voicemail. If you do not locate and disclose the voicemail at the outset, you may be barred from using it to prove your case.You may have an affirmative duty to maintain your voicemail records. Because digitized voicemail is discoverable, failing to maintain this data may constitute "spoliation" of evidence, meaning that if you fail to preserve key voicemail messages that your adversary claims are relevant, you may be barred from contradicting the evidence that your adversary claims was contained in the voicemail. Digitized voicemail messages may constitute "records" under federal and state statutory schemes, including the new Sarbanes-Oxley bill, that require companies to maintain records of certain activities for specific periods of time.

Waiver in Prenup Doesn't Bar Request for Attorneys' Fees
A woman whose prenuptial agreement precludes either spouse from seeking legal fees from the other in the event of a divorce may nonetheless request a fee award against her millionaire husband, the New York Appellate Division rules. The court says that while the bar on fees is not inherently invalid, it is against public policy in this case due to the immense disparity in the couple's finances. It also announces a rule to be applied when dealing with fee waiver provisions. See Kessler v, Kessler, N.Y. App. Div., No. 2004-04773, 7/11/06.For assitance with prenuptial agreements, contact NRG - Nirenstein Ruotolo Group, P.L.C.

Mother's Veracity Irrelevant In Paternity Case -- Estoppel
The paternity by estoppel doctrine does not contain an exception for men who accept the role of fatherhood based on misrepresentations by the subject child's mother, the New York Court of Appeals says. Explaining that the mother's truthfulness is irrelevant and that the child's best interests control, it affirms filiation and support orders entered against a New York man who had been led to believe he fathered a child in Guyana after dating a woman there in 1995. See Shondel J. v. Mark D., N.Y., No. 46, 7/6/06.For issues regarding paternity, and other child-related legal issues, contact NRG - Nirenstein Ruotolo Group, P.L.C.

Enraged Doctor Burns Residence - The Real War of The Roses
This New York case, brought to our attention by Jeanne M. Hanna, Esq., author of "Updates in Michigan Family Law" is a prime example of the lengths people are willing to go to keep the marital residence from the other spouse. See the Article.For Arizona Divorce Issues, contact Nirenstein Ruotolo Group.

Arizona Granparent Rights Decision
Grandparent rights case not dismissed from superior court where jurisdiction was based on child being born out-of-wedlock, when subsequently parents remarry. See Fry v. Garcia, CA-CV 05-0663.For Arizona Grandparent Rights matters contact Nirenstein Ruotolo Group.

Ninth Circuit Rules On Non-Custodial Parent's Rights
The Ninth Circuit Court of Appeals (Arizona's circuit court) recently ruled that non-custodial parents with court-ordered visitation rights have a liberty interest in the companionship, care, custody, and management of their children. Brittain v. Hansen (06/22/06 - No. 03-57012). For Arizona Custody Issues contact NRG Family Law.

Colorado Allows 12-Year-Old Girls To Enter Into Common-Law Marriages
Trial court erred in holding that a 15-year-old girl's marriage to an adult man was void ad initio because they did not obtain judicial consent, the Colorado Court of Appeals held June 15. Pointing out that Colorado recognizes common-law marriage, the court noted that there is no statutory provision indicating that the state does not follow the common-law age of consent for marriage, which is age 12 for girls. Thus, it said that so long as all other elements of a common-law marriage are present, the couple's marriage is valid. In re J.M.H., Colo. Ct. App., No. 04CA0740, 6/15/06. For information regarding Common Law Marriages in Arizona, contact NRG Family Law, Arizona's Premier Family Law Firm.The man (who is now 38) and the girl began living together in 2002. They applied for a marriage license in 2003, when she was 15. The girl's mother offered her signed and notarized consent to the marriage, and accompanied them to the county clerk's office to obtain a marriage license. The clerk approved the application and returned it by mail, stating that they were fully registered as a legal married couple. In 2004, the county department of human services petitioned to declare the marriage invalid. The trial court granted the petition, holding that a person under the age of 16 must obtain judicial approval for a valid common-law or ceremonial marriage. It ruled that the marriage was void ab initio under the state's Uniform Dissolution of Marriage Act, which requires a court to find that an underage party is capable of assuming the responsibilities of marriage and that entering into a marriage would serve that party's best interests. UMA Reversing, Judge Daniel M. Taubman looked to the state's Uniform Marriage Act, which sets forth the rules and requirements for ceremonial marriages in Colorado. He noted that the UMA provides that the statutory age of consent for marriage is 18 and that persons between the ages of 16 and 18 may marry if they obtain parental consent, or if that is not possible, judicial approval. Taubman pointed out, however, that the UMA also provides that "[n]othing in this section shall be deemed to repeal or render invalid any otherwise valid common-law marriage between one man and one woman." Colo. Rev. Stat. ?? 14-2-104(3) (2005). Explaining that Colorado is one of several states that still recognizes common-law marriage, he said that such marriages are governed by common law, not the UMA. Common Law Prevails Finding that Colorado appellate courts had not previously determined the age of consent for a valid common-law marriage, Taubman looked to the origins of common law in Colorado and to other jurisdictions for guidance. He observed that Colorado statutory law provides that the "common law of England ... shall be considered as of full force until repealed by legislative authority." ?? 2-4-211. Thus, absent clear legislative intent, the common law prevails in any conflict with statutory law, Taubman said. Also noting that the U.S. Supreme Court, in Meister v. Moore, 96 U.S. 76 (1877), held that common-law marriages are valid--notwithstanding statutes that require ceremonial marriages to be solemnized by a minister or a magistrate--if no specific provision to the contrary exists, Taubman found that other jurisdictions have followed this approach. He added that statutes prescribing the procurement of a license and other formalities to be observed in the solemnization of a marriage do not render invalid a marriage entered into according to the common law--but not in conformity with the statutory formalities--unless the statutes themselves expressly declare such a marriage invalid. Age of Consent Taubman determined that courts in other jurisdictions have uniformly declared that the common-law age of consent applies to common-law marriages, even when statutes otherwise require parental or judicial approval for persons under a specified age, unless such statutes expressly modify or abrogate the common law. Taking note of the ruling in State v. Wade, 766 P.2d 811 (Kan. 1989), that the common-law marriage of a person is valid, regardless of whether the person has reached the age of competency as established by statute, if the person is competent, he observed that under English common law, children above the age of seven could marry, but that such marriage was voidable until the parties reached an age at which they became able to consummate it, which the law presumed to be 14 for males and 12 for females. Going on to note that several jurisdictions have adopted those ages as the common-law ages of consent for marriage, Taubman ruled that the court below erroneously held that persons under the age of 16 may not enter into a valid common-law marriage without judicial approval. He pointed out that neither the UDMA nor the UMA makes any reference, either express or implied, to (1) common-law marriages in general; (2) abrogation or modification of the common law regarding the age of consent for common-law marriage; or (3) the need for any formalities, such as parental consent, to solemnize a common-law marriage between an adult and a minor. Taubman further noted that the Uniform Marriage and Divorce Act, upon which the UDMA is substantially based, also does not address such issues. Valid Ab Initio "Thus, in the absence of a statutory provision to the contrary, it appears that Colorado has adopted the common-law age of consent for marriage as fourteen for a male and twelve for a female, which existed under English common law. Nevertheless, we need only hold here that a fifteen-year-old girl may enter into a valid common-law marriage," Taubman decided. Taubman went on to say that if all other elements for a common marriage were satisfied in this case, the girl's marriage to the man was valid ab initio because she was competent at common law on the date she was married. Holding therefore that the trial court erred when it required the man to obtain judicial approval for his common-law marriage to the girl, he remanded for an evidentiary hearing addressing whether the elements necessary for establishing a common-law marriage, other than the age of consent, were met.

Colorado Allows 12-Year-Old Girls To Enter Into Common-Law Marriages
Trial court erred in holding that a 15-year-old girl's marriage to an adult man was void ad initio because they did not obtain judicial consent, the Colorado Court of Appeals held June 15. Pointing out that Colorado recognizes common-law marriage, the court noted that there is no statutory provision indicating that the state does not follow the common-law age of consent for marriage, which is age 12 for girls. Thus, it said that so long as all other elements of a common-law marriage are present, the couple's marriage is valid. In re J.M.H., Colo. Ct. App., No. 04CA0740, 6/15/06) For information regarding Common Law Marriages in Arizona, contact NRG Family Law, Arizona's Premier Family Law Firm.The man (who is now 38) and the girl began living together in 2002. They applied for a marriage license in 2003, when she was 15. The girl's mother offered her signed and notarized consent to the marriage, and accompanied them to the county clerk's office to obtain a marriage license. The clerk approved the application and returned it by mail, stating that they were fully registered as a legal married couple. In 2004, the county department of human services petitioned to declare the marriage invalid. The trial court granted the petition, holding that a person under the age of 16 must obtain judicial approval for a valid common-law or ceremonial marriage. It ruled that the marriage was void ab initio under the state's Uniform Dissolution of Marriage Act, which requires a court to find that an underage party is capable of assuming the responsibilities of marriage and that entering into a marriage would serve that party's best interests. UMA Reversing, Judge Daniel M. Taubman looked to the state's Uniform Marriage Act, which sets forth the rules and requirements for ceremonial marriages in Colorado. He noted that the UMA provides that the statutory age of consent for marriage is 18 and that persons between the ages of 16 and 18 may marry if they obtain parental consent, or if that is not possible, judicial approval. Taubman pointed out, however, that the UMA also provides that "[n]othing in this section shall be deemed to repeal or render invalid any otherwise valid common-law marriage between one man and one woman." Colo. Rev. Stat. ?? 14-2-104(3) (2005). Explaining that Colorado is one of several states that still recognizes common-law marriage, he said that such marriages are governed by common law, not the UMA. Common Law Prevails Finding that Colorado appellate courts had not previously determined the age of consent for a valid common-law marriage, Taubman looked to the origins of common law in Colorado and to other jurisdictions for guidance. He observed that Colorado statutory law provides that the "common law of England ... shall be considered as of full force until repealed by legislative authority." ?? 2-4-211. Thus, absent clear legislative intent, the common law prevails in any conflict with statutory law, Taubman said. Also noting that the U.S. Supreme Court, in Meister v. Moore, 96 U.S. 76 (1877), held that common-law marriages are valid--notwithstanding statutes that require ceremonial marriages to be solemnized by a minister or a magistrate--if no specific provision to the contrary exists, Taubman found that other jurisdictions have followed this approach. He added that statutes prescribing the procurement of a license and other formalities to be observed in the solemnization of a marriage do not render invalid a marriage entered into according to the common law--but not in conformity with the statutory formalities--unless the statutes themselves expressly declare such a marriage invalid. Age of Consent Taubman determined that courts in other jurisdictions have uniformly declared that the common-law age of consent applies to common-law marriages, even when statutes otherwise require parental or judicial approval for persons under a specified age, unless such statutes expressly modify or abrogate the common law. Taking note of the ruling in State v. Wade, 766 P.2d 811 (Kan. 1989), that the common-law marriage of a person is valid, regardless of whether the person has reached the age of competency as established by statute, if the person is competent, he observed that under English common law, children above the age of seven could marry, but that such marriage was voidable until the parties reached an age at which they became able to consummate it, which the law presumed to be 14 for males and 12 for females. Going on to note that several jurisdictions have adopted those ages as the common-law ages of consent for marriage, Taubman ruled that the court below erroneously held that persons under the age of 16 may not enter into a valid common-law marriage without judicial approval. He pointed out that neither the UDMA nor the UMA makes any reference, either express or implied, to (1) common-law marriages in general; (2) abrogation or modification of the common law regarding the age of consent for common-law marriage; or (3) the need for any formalities, such as parental consent, to solemnize a common-law marriage between an adult and a minor. Taubman further noted that the Uniform Marriage and Divorce Act, upon which the UDMA is substantially based, also does not address such issues. Valid Ab Initio "Thus, in the absence of a statutory provision to the contrary, it appears that Colorado has adopted the common-law age of consent for marriage as fourteen for a male and twelve for a female, which existed under English common law. Nevertheless, we need only hold here that a fifteen-year-old girl may enter into a valid common-law marriage," Taubman decided. Taubman went on to say that if all other elements for a common marriage were satisfied in this case, the girl's marriage to the man was valid ab initio because she was competent at common law on the date she was married. Holding therefore that the trial court erred when it required the man to obtain judicial approval for his common-law marriage to the girl, he remanded for an evidentiary hearing addressing whether the elements necessary for establishing a common-law marriage, other than the age of consent, were met.

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