Certified for Partial Publication.
DAVIS, J.
A jury convicted defendant Robert Nelson Atkins of arson of forest land, found he had two prior convictions that qualified as "strikes" under the three strikes law (a 1983 robbery conviction and a 1991 firearm assault conviction), and found that the 1991 conviction was a serious felony for which he had served a recent prison sentence. (Pen.Code, §§ 451, subd. (c); 667, subds...
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