Does a defendant have to obtain a certificate of probable cause to challenge a motion waiving custody credit for a probation matter?

Because the custody credit defendant had earned comprised her entire sentence in the probation matter, waiving that credit for the new case ensured she would serve that sentence consecutively to rather than concurrently to her new sentence. As such, it was an integral term of the plea agreementand because it was an integral term of the agreement, to challenge it, defendant was required to obtain a certificate of probable cause. (People v. Buttram, supra, 30 Cal.4th at pp. 781-782.)

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