California, United States of America
The following excerpt is from People v. Mickens, 2d Crim. No. B269152 (Cal. App. 2016):
We appointed counsel to represent him on this appeal. After examination of the record, his counsel filed an opening brief requesting the court to make an independent review under People v. Wende (1979) 25 Cal.3d 436. In her declaration, counsel said that in a letter dated March 23, 2016, she advised appellant that he had 30 days to file a supplemental brief.
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