California, United States of America
The following excerpt is from People v. Olivarez, D058082, Super. Ct. No. RIF129919 (Cal. App. 2011):
The Attorney General acknowledges that Olivarez is correct. (People v. Oganesyan (1999) 70 Cal.App.4th 1178, 1184-1186 [ 1202.45 fine is not applicable to term of life in prison without the possibility of parole]; People v. Zackery (2007) 147 Cal.App.4th 380, 385 [oral pronouncement controls over minute order].)
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