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The traditional view that the representation must be of a present or past fact, and that a mere promise to perform an act in the future will not support a conviction, is expressed in the following cases: People v. Wasservogle (1888), 77 Cal. 173, 174 [19 P. 270]; People v. Green (1913), 22 Cal.App. 45, 48, 51 [133 P. 334] [conviction reversed because defendant's statements which induced victim to part with property were promises, not misrepresentations of fact]; People v. Kahler (1915), 26 Cal.App. 449, 452 [147 P. 228] [same]; In re James (1920), 47 Cal.App. 205, 206 [190 P. 466]; People v. Mace (1925), 71 Cal.App. 10, 21 [234 P. 841]; People v. Walker (1926), 76 Cal.App. 192, 205 [244 P. 94]; People v. Moore (1927), 82 Cal.App. 739, 746 [256 P. 266]; People v. White (1927), 85 Cal.App. 241, 250 [259 P. 76]; People v. Cale (1930), 106 Cal.App.Supp. 777, 780 [288 P. 430] [conviction reversed because representations were in form of promises]; People v. Robinson (1930), 107 Cal.App. 211, 221 [290 P. 470]; People v. Reese (1934), 136 Cal.App. 657, 663 [29 P.2d 450] [conviction reversed because representations were as to ...

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