Chief Justice BERCH, opinion of the Court.
¶ 1 Arizona Rule of Criminal Procedure 31.3 requires that a notice of appeal be filed "within 20 days after the entry of judgment and sentence." We granted review to determine whether "entry," as used in Rule 31.3, occurs when the judge pronounces the sentence in open court or instead when the clerk files the minute entry memorializing the judgment and sentence. We conclude that entry occurs when the sentence is pronounced...
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