What is the test for making diligent efforts to identify an informant on her own?

California, United States of America


The following excerpt is from The People v. Pelt, A124906, No. 205154-02 (Cal. App. 2011):

1. We agree with defendant the trial court was wrong in denying defendant's motion on the ground she had not made diligent efforts to identify the informant on her own. (See Twiggs v. Superior Court (1983) 34 Cal.3d 360, 365 ["the duty to disclose arises irrespective of the defendant's ability to obtain the information through his own efforts"].) As discussed below, we affirm on other grounds.

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