California, United States of America
The following excerpt is from People v. Orosco-Hernandez, C084852 (Cal. App. 2018):
Here, defendant challenges the evidence supporting the third and fifth elements of his criminal threat conviction. Defendant's argument raised for the first time in reply concerning the fourth element is likely forfeited (People v. Duff (2014) 58 Cal.4th 527, 550, fn. 9), but in any event, it is unmeritorious. Substantial evidence supports the judgment.
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