California, United States of America
The following excerpt is from People v. Tran, H038262 (Cal. App. 2016):
(People v. Cunningham (2001) 25 Cal.4th 926, 992.) The suspect must clearly assert the right to counsel, after which interrogation must cease until counsel is made available unless the suspect initiates further communication. (Edwards v. Arizona (1981) 451 U.S. 477, 484-485.)
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