Critically discuss with reference to at least three criminal jurisdictions, including at least one example from the common law and one example from the civil law legal families.

Topic:
Minimal convergence of criminal procedure has occurred in recent developments in the common law and civil law legal families. Critically discuss with reference to at least three criminal jurisdictions, including at least one example from the common law and one example from the civil law legal families (you may choose to discuss jurisdictions outside theses families also, so long as you relate any such exampls to the issue of convergence in the question

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