California, United States of America
The following excerpt is from People v. Saragoza, C074012 (Cal. App. 2014):
Defense counsel argued that the claimed expenses had not been verified by law enforcement to be necessary for the personal safety of the victim as required by section 1202.4 (f)(3)(I). He further argued that the expenses were not economic losses resulting from defendant's conduct such as those contemplated by People v. Mearns (2002) 97 Cal.App.4th 493 (Mearns) where the victim "simply had to move" due to defendant's conduct.
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