California, United States of America
The following excerpt is from People v. Range, A158852 (Cal. App. 2021):
Defendant's counsel filed an opening brief asking that this court conduct an independent review of the record for arguable issuesi.e., those that are not frivolous, as required by People v. Wende (1979) 25 Cal.3d 436 (Wende). Counsel also informed defendant that he had the right to file a supplemental brief on his own behalf, but defendant declined to do so.
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