Defendant, who neither speaks nor understands English, was a passenger in a car lawfully stopped by police for a traffic infraction. The driver was told to turn off the ignition and get out of the car. When the driver got out, the defendant got out and, in doing so, exposed a gun in his waistband. He was arrested and a later search revealed bullets and cocaine. We do not know that the defendant's action in getting out of the car arose from the driver's action in getting out...
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