Superior Court of Pennsylvania July 12, 1978, 913 (Commonwealth v. Fiorini)

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United States · · · 12-07-1978

SPAETH, Judge,

concurring:

I cannot agree with the majority’s statement that the evidence disclosed a modus operandi. A modus operandi is a method of operating “so unusual and distinctive as to be like a signature.” McCormick on Evidence § 190 at 449 (Cleary Ed. 1972). And see Commonwealth v. Peterson, 453 Pa. 187, 307 A.2d 264 (1973).

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