The following excerpt is from U.S. v. Martinez, 972 F.2d 1100 (9th Cir. 1992):
1 Whether law enforcement officers may initiate interrogation of a suspect who previously requested counsel is a question of law that we review de novo. See United States v. DeSantis, 870 F.2d 536, 538 (9th Cir.1989).
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