That stamped rear cover can bend at the bolt holes, just like a valve cover. Pull the rear cover and check it for straightness. I did mine and no more leaks.
Also, spray some kind of sealant on the shims. Pull the shims apart and clean. Then use some type of sealant (I've had good luck with HiTack spray) on one side of each shim and the rear cover. Assemble so there is sealant in between each shim.
Oh, and remember to use a thread sealant on the bolts. Most of the bolts on the Dana 20 are drilled through the case, requiring sealant on the bolts to keep them from leaking.