California, United States of America
The following excerpt is from Dawson v. Superior Court In and For Alameda County, 138 Cal.App.2d 685, 292 P.2d 574 (Cal. App. 1956):
In People v. Howes, 99 Cal.App.2d 808, 222 P.2d 969, where the thefts were committed by larceny, this court reviewed the situation in California concerning the problem of whether a series of thefts constitute one offense or a series of offenses, and pointed out that generally there has been a distinction between thefts accomplished by means of false representations and those accomplished by larceny by trick or device or by embezzlement.
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