California, United States of America
The following excerpt is from People v. Alvarez, F078551 (Cal. App. 2021):
34. Granted, this is defense counsel's version of events. However, to the extent defendant would seek to disprove counsel's assertions with evidence outside the record, that cannot be done on direct appeal. (See People v. Arce (2014) 226 Cal.App.4th 924, 930.)
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