California, United States of America
The following excerpt is from People v. Vlahos-Schmidt, A133704 (Cal. App. 2013):
The Attorney General does not attempt to defend the discovery sanction aspect of the court's ruling. Our own review of section 1054.3, which governs the defense's disclosure obligation to the prosecution, does not reveal any legal basis for the court's ruling. On the contrary, case law interprets section 1054.3 as "requir[ing] defense counsel to disclose to the prosecution all relevant statements made by persons, other than the defendant, whom the defense intends to call as witnesses at trial, including unrecorded oral statements relayed to defense counsel in an oral report by a third party, such as an investigator, and oral statements made by the person directly to defense counsel." (Roland v. Superior Court (2004) 124 Cal.App.4th 154, 160, second italics added.)
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