The following excerpt is from Ramirez v. Lynch, 810 F.3d 1127 (9th Cir. 2016):
There is an exception to the juror unanimity requirement, for a "continuous course of conduct." In the context of section 273a(a), a prosecutor can allege a pattern of abuse, and, in such a case, the jury need not agree unanimously as to which specific acts the defendant committed within that pattern. People v. Ewing, 72 Cal.App.3d 714, 140 Cal.Rptr. 299, 301 (1977). "Although the child abuse statute may be violated by a single act, more commonly it covers repetitive or continuous conduct." Id. (citation omitted).
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