Does the police need to undertake a Miranda readvisement if a subsequent interrogation is reasonably contemporaneous with the prior waiver?

Where a subsequent interrogation is " reasonably contemporaneous " with the prior waiver, and the prior waiver was "knowing and intelligent," police need not undertake a Miranda readvisement. ( People v. Mickle (1991) 54 Cal.3d 140, 170, 284 Cal.Rptr. 511, 814 P.2d 290 ( Mickle ).) In determining whether a subsequent interrogation is reasonably contemporaneous, we consider the totality of the circumstances. Relevant considerations include: "1) the amount of time that has passed since the initial waiver; 2) any change in the identity of the interrogator or location of the interrogation; 3) an official reminder of the prior advisement; 4) the suspects sophistication or past experience with law enforcement; and 5) further indicia that the defendant subjectively understands and waives his rights." ( People v. Smith (2007) 40 Cal.4th 483, 504, 54 Cal.Rptr.3d 245, 150 P.3d 1224 ( Smith ).)

[420 P.3d 1122]