California, United States of America
The following excerpt is from People v. Preston, 43 Cal.App.4th 450, 50 Cal.Rptr.2d 778 (Cal. App. 1996):
It will be noted that nothing in the present statute requires that the restitution demand be made prior to commencement of criminal proceedings. Since defendant finds such a requirement in the cases, we turn to them.
PEOPLE v. MCGEE AND OTHER PRE-1984 CASES
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