California, United States of America
The following excerpt is from People v. Parento, 1 Cal.Rptr.2d 444, 235 Cal.App.3d 1378 (Cal. App. 1991):
"Did the trial court err in allowing the trial to proceed in appellant's absence and without representation by counsel?" (See People v. Brownlee (1977) 74 Cal.App.3d 921, 931, 141 Cal.Rptr. 685; People v. Carroll (1983) 140 Cal.App.3d 135, 142-144, 189 Cal.Rptr. 327.)
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