California, United States of America
The following excerpt is from People v. Rosenschein, E071453 (Cal. App. 2019):
Padfield (1982) 136 Cal.App.3d 218, 226 [holding defendant forfeited statute of limitations defense when charging document alleged defendant committed crime within statute of limitations period and defendant pled no contest]; People v. Simmons, supra, 210 Cal.App.4th at p. 793 ["We also conclude that a defendant may forfeit factual issues relating to the statute of limitations when, as here, the information alleges facts indicating that the prosecution was timely."].)
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