California, United States of America
The following excerpt is from People v. Thomas, D064220 (Cal. App. 2014):
However, it is well-established that "probation revocation is not part of a criminal prosecution, and thus 'the full panoply of rights due a defendant in [a criminal] proceeding does not apply . . . .'" (People v. Shepherd (2007) 151 Cal.App.4th 1193, right of confrontation . . . is not absolute, and where '"appropriate,"' witnesses may give evidence by '"affidavits, deposition, and documentary evidence. . . ."'" (Shepherd, at pp. 1193, 1198, quoting People v. Winson (1981) 29 Cal.3d 711, 716.)
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