State v. Juan Pablo Santos (067989; A-114-10)
The grant of an evidentiary hearing in which defendant
was to be permitted to provide telephonic testimony
must be reversed and the matter remanded for full
reconsideration by the post-conviction relief (PCR)
court as to whether defendant can meet the standard
for entitlement to an evidentiary hearing under State
v. Gaitan, 209 N.J. 339 (2012). 5-8-12
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