California, United States of America
The following excerpt is from People v. Ayala, G052443 (Cal. App. 2017):
(People v. Anderson (1975) 15 Cal.3d 806, 809 ["[a] criminal defendant must be given fair notice of the charges against him in order that he may have a reasonable opportunity to properly prepare a defense and avoid unfair surprise at trial"].) Several reasons lead us to this conclusion.
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