The following excerpt is from U.S. v. Kelm, 827 F.2d 1319 (9th Cir. 1987):
1 It should be noted that, in respect to this line of cases, a majority of the circuits have adopted a nonformalistic approach to determining sufficiency of the waiver from the record as a whole rather than requiring a deliberate and searching inquiry. See United States v. McDowell, 814 F.2d 245, 249 (6th Cir.1987).
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