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P. v. Brown CA1/1
Defendant Carl Ray Brown Jr. was ordered to pay $6,970.40 in restitution for relocation expenses, $6,820.40 payable to the Victim Compensation Board and $150 payable directly to the victim, his former wife. He challenges the restitution for relocation expenses on several grounds. He first claims the law enforcement verification form submitted to establish that the relocation expenses were “necessary for the personal safety of the victim” is too cursory to satisfy the statutory verification requirement. He next claims the evidence does not support a finding that relocation was necessary for the safety of the victim. He additionally claims the restitution cannot be upheld on the alternative ground relocation was necessary for the “emotional well-being of the victim” given the absence of statutorily required verification by a mental health treatment provider. (Ibid.) Although it is a close call whether the law enforcement verification is adequate, we affirm.

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