California, United States of America
The following excerpt is from People v. M.F. (In re M.F.), 2d Juv. No. B293804 (Cal. App. 2019):
2. Appellant argues that a phone video shows that excessive force was used, but the video only depicted the arrest, after appellant was lying on the ground. The trial court "admitted [the video] by reference" but did not receive the video into evidence, nor did appellant provide a copy of the video or a transcript of its contents. (Cal. Rules of Court, rule 2.1040(b).) The video is not part of the record on appeal and may not be considered on appeal. (Frank v. County of Los Angeles (2007) 149 Cal.App.4th 805, 815.)
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