The following excerpt is from People v. Williams, 114 N.Y.S.3d 815 (Table), 63 Misc.3d 1223 (A) (N.Y. Cty. Ct. 2019):
"The inculpatory statements made by defendant after he invoked his right to counsel were spontaneous and not the result of police interrogation or its functional equivalent" ( People v. Lipscomb , 214 AD2d 970, 970 [4th Dept 1995], citing People v. Rivers, 56 NY2d 476, 479480, rearg. denied 57 NY2d 775 ). Further, "the police are under no affirmative obligation to prevent a talkative person in custody from making incriminating statements ( People v. Rivers, supra, 56 NY2d at 479 ).
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