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P. v. Markell CA1/1
Defendant was convicted by a jury of two counts of making criminal threats against two victims. Defendant contends the trial court erred by failing to instruct sua sponte on unanimity. Because defendant was engaged in a continuous course of conduct, the prosecution was not required to make an election of a discrete criminal act, and thus the court was not obligated to sua sponte give a unanimity instruction. We therefore affirm.

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