California, United States of America
The following excerpt is from People v. Rouse, H034647 (Cal. App. 2012):
We review the trial court's determination independently. (People v. Manriquez (2005) 37 Cal.4th 547, 581.) (We note that the court stated of defendant's request that "we discussed this informally" in a "discussion off the record," and the court's reasons for denying the request do not appear in the record at the point at which the court made these observations.)
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