P. v. Lowe
Defendant Joshua Michael Lowe was convicted of multiple charges related to a series of vehicle burglaries. On appeal, defendant requests this court review the sealed documents related to his Pitchess motion (Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess)) to determine whether the trial court abused its discretion in determining there were no discoverable materials (Evid. Code, § 1043 et seq.). Because the trial court failed to swear in the custodian of records at the in camera hearing, we remand the case to the trial court with directions to hold a new hearing in which the oath is administered to the custodian of records before he testifies.
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