Kim Basinger and Alec Baldwin's latest court hearing has been held in private after a judge said their daughter found the public row "emotionally traumatic".
Kim Basinger and Alec Baldwin were married for almost nine years
The actors, who divorced five years ago, are locked in a bitter custody battle over 11-year-old Ireland.
It escalated two weeks ago when Baldwin was heard in a leaked phone message calling the girl a "thoughtless pig".
Superior Court Commissioner Maren Nelson said the media were banned to protect "the well-being of the child".
She closed Friday's session to the public soon after it began and sealed records filed in connection with the hearing.
"I recognise there is significant media interest in this matter," she said. "[But] it's not in the best interests of the child for this to be further broadcast by the media."
Kim Basinger sat in the back row of the gallery at the hearing
Basinger was present at the hearing but Baldwin was not, saying he feared his comments would be leaked to the media.
There were reports that the hearing was held to decide whether to alter Baldwin's visiting rights in the wake of the tape revelation.
Basinger's lawyer Neal Hersh said a decision was reached but he would not reveal the outcome.
"We are very, very pleased with the judge's thoughtful decision about what happened here today," he said afterwards.
Baldwin's lawyer Vicki Greene said the leaking of the voicemail was "not appropriate, and it's not in Ireland's best interest, and it will be with her for the rest of her life".
Baldwin has said he was "driven to the edge by parental alienation"
A further hearing will be held on 5 June to investigate who leaked the tape.
Baldwin recently appeared on US TV to apologise for his rant. In an earlier statement, he said he was "driven to the edge by parental alienation for many years".
The actor's rant, in which he accused his daughter of humiliating him, was apparently sparked by his repeated failure to reach her by telephone.
The message said: "You don't have the brains or the decency as a human being... I don't give a damn that you're 12 years old or 11 years old or that you're a child or that your mother is a thoughtless pain in the ass."
He also threatened to "straighten your ass out" during a forthcoming visit.