California, United States of America
The following excerpt is from People v. Ruiz, A139127 (Cal. App. 2016):
Nor are we persuaded by appellants' reliance on People v. Santamaria (1991) 229 Cal.App.3d 269, 277 (Santamaria), in which the court held an adjournment of 10 days during jury deliberations was an abuse of discretion where it could have been avoided by transferring the case to another judge as requested by the parties. The issue of forfeiture was not raised on appeal in Santamaria until the People filed a petition for rehearing, which prompted the court to add a footnote to its opinion stating that the
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