California, United States of America
The following excerpt is from People v. Dowell, G052630 (Cal. App. 2017):
Reasonable or due diligence means "'"persevering application, untiring efforts in good earnest, efforts of a substantial character."'" (People v. Cogswell (2010) 48 Cal.4th 467, 477.) Considerations "include the timeliness of the search, the
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