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P. v. Garbin CA6
On April 1, 2016, defendant Raymond Anthony Garbin pleaded no contest to 10 counts of felony identity theft (Pen. Code, § 530.5, subd. (a)) after the enactment of Proposition 47, which reclassified certain felony drug and theft related offenses as misdemeanors. (Prop. 47, as approved by voters, Gen. Elec. (Nov. 4, 2014), eff. Nov. 5, 2014.) The trial court sentenced defendant to a stipulated sentence of six years eight months, and defendant appealed from the judgment. Defendant’s appellate counsel filed an opening brief in which no issues were raised and asked this court for an independent review of the record as required by People v. Wende (1979) 25 Cal.3d 436 (Wende). After defendant was notified that an independent Wende review was requested, he submitted a letter brief arguing that Proposition 47 reduced his felonies to misdemeanors, among other claims.

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