California, United States of America
The following excerpt is from People v. Fellows, B280629 (Cal. App. 2018):
even a recent one, does not negate the otherwise extensive efforts made by investigators to check addresses. (See People v. Andrade (2015) 238 Cal.App.4th 1274, 1294 [failure to conduct a physical check of the last known address of witness's mother and grandmother "does not transform [an] otherwise exhaustive effort into an unreasonable one, lacking the requisite diligence"].)
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