California, United States of America
The following excerpt is from Buchanan v. Buchanan, 160 Cal.Rptr. 577, 99 Cal.App.3d 587 (Cal. App. 1979):
In Lyons v. Superior Court, 73 Cal.App.3d 625, 628, 140 Cal.Rptr. 826, the court held that where the same judge hears the plea bargain and sentencing, the 170.6 challenge must be made before the plea bargain and is untimely if made before sentencing.
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