California, United States of America
The following excerpt is from In re Corpus, G046534 (Cal. App. 2017):
"Because appellate courts are ill-suited to conduct evidentiary hearings, it is customary for appellate courts to appoint a referee to take evidence and make recommendations as to the resolution of disputed factual issues." (People v. Romero (1994) 8 Cal.4th 728, 740.) "The central reason for referring a habeas corpus claim for
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