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What Do The Special Circumstances In The D4VD Charges Actually Mean?

The charges filed against David Anthony Burke in the death of Celeste Rivas Hernandez represent the most serious allegations available under California law. This look back examines the charge sheet in detail and analyzes the prosecution's theory as constructed through the specific charges and special circumstances alleged.First-degree murder is accompanied by three special circumstances: lying in wait, financial gain, and the killing of a witness. The financial-gain allegation is specific — prosecutors contend Burke allegedly killed Celeste because she was threatening to expose a relationship…

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