California, United States of America
The following excerpt is from People v. Reyes, B266696 (Cal. App. 2017):
Appellant relies principally on the case of People v. Sandoval (2001) 87 Cal.App.4th 1425 (Sandoval), in which a witness who testified at the preliminary hearing was unavailable to testify at trial. Sandoval stated that the question presented was "whether the prosecution, to establish the unavailability of a crucial witness who is a Mexican citizen currently residing in Mexico, must show it made a reasonable, good faith effort to obtain the attendance of the witness at trial. We conclude the defendants' right of confrontation requires such a showing. Since no such showing was made here, we reverse the defendants' convictions for murder and related crimes." (Id. at p. 1428, italics added.)
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