California, United States of America
The following excerpt is from People v. American Bankers Ins. Co., 191 Cal.App.3d 742, 236 Cal.Rptr. 501 (Cal. App. 1987):
[191 Cal.App.3d 747] Neither section 977, subdivision (a) nor section 1043, subdivision (e) require the attorney's authorization to be in writing. 3 Thus, without a strong factual showing to the contrary (see Sarracino v. Superior Court (1974) 13 Cal.3d 1, 13, 118 Cal.Rptr. 21, 529 P.2d 53), the attorney's representation that he or she is authorized to proceed in the defendant's absence is sufficient.
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