California, United States of America
The following excerpt is from People v. Carr, B225581, Super. Ct. No. BA365758 (Cal. App. 2011):
"A trial court's decision on the discoverability of material in police files is reviewable under an abuse of discretion standard." (People v. Jackson (1996) 13 Cal.4th 1164, 1220.) We independently review the sealed transcript. (See People v. Hughes (2002) 27 Cal.4th 287, 330.)
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