California, United States of America
The following excerpt is from People v. Castro, B230675 (Cal. App. 2013):
Appellant was properly advised of his Miranda rights, which he stated that he understood. He also said that he would waive his right to have counsel present when talking to the detectives. Appellant signed the Miranda waiver form corroborating these oral agreements. "An express written or oral statement of waiver of the right to remain silent or of the right to counsel is usually strong proof of the validity of that waiver . . ." (North Carolina v. Butler, supra, 441 U.S. at p. 373.)
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