California, United States of America
The following excerpt is from People v. Garfield, 160 Cal.App.3d 1139, 207 Cal.Rptr. 353 (Cal. App. 1984):
6 We are aware that in People v. Olson (1965) 232 Cal.App.2d 480, 42 Cal.Rptr. 760, the court found that the filing of a fraudulent "bid" in alleged violation of section 115 was not a falsification of public records within the meaning of section 799 because (1) the bid lacked the "character" and "dignity" of a public record; and (2) the bid was neither forged nor changed after its original complete preparation. (Id., at p. 487, 42 Cal.Rptr. 760.)
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