California, United States of America
The following excerpt is from The People v. Huber, F057731, No. 1226483 (Cal. App. 2010):
In Ryan, the defendant signed another person's name to two checks and then used those checks to make purchases at two different stores. As to each store, the defendant was convicted of one count of forgery by signing another's name under section 470, subdivision (a) and one count of passing a forged check, under section 470, subdivision (d). We reversed the judgment of conviction on the counts alleged under subdivision (a), holding that the various subdivisions of sections 470 described different ways of committing the same crime, and that a defendant could not suffer multiple convictions for forgery based on a single instrument. We quoted People v. Frank (1865) 28 Cal. 507, 513, as follows:
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