California, United States of America
The following excerpt is from People v. Rosas, D072623 (Cal. App. 2018):
Rosas correctly notes that the mere fact that additional efforts could have been pursued does not necessarily render the proponent's efforts unreasonable. (See, e.g., People v. Cummings (1993) 4 Cal.4th 1233, 1298 (Cummings).) But, as Rosas acknowledges, the efforts the proponent does undertake must be reasonable under the circumstances. Here, for the reasons explained above, Rosas's efforts were not reasonable.
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