California, United States of America
The following excerpt is from People v. Rios, G044142, Super. Ct. No. 08NF3676 (Cal. App. 2011):
[citations]: '[A]n accused, . . . having expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him' [citations] and indeed until counsel is actually present [citation], 'unless the accused himself initiates further communication, exchanges, or conversations with the police.' [Citations.]" (People v. Waidla (2000) 22 Cal.4th 690, 727 (Waidla), italics added.)
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