pertinent charge of aggravated assault, to sentence defendant to life imprisonment without possibility of release before serving twenty-five years. One element in this mandatory sentence was defendant’s probationary status at the time of the crime. See A.R.S. § 13-604.02 (1989). Defendant argues on appeal that this element was improperly established at trial. After the jury was excused, instead of requiring proof of probationary status, the trial judge stated that he had been the sentencing judge for defendant’s probation violation proceeding, and he took judicial notice that defendant was on probation at the time of his crime. Defense counsel did not object. The defendant now argues on appeal that this was error, relying on State v. Lee, 114 Ariz. 101, 105, 559 P.2d 657, 661 (1976) (<HOLDING>), and State v. Hurley, 154 Ariz. 124, 132, 741
holding that the proper procedure to prove prior convictions is to offer a certified copy of the conviction holding that when an agency fails to follow the proper procedure under the illinois administrative procedure act for the adoption of rules the rule is invalid holding that the state had the burden of proving the defendants two prior convictions in order to obtain the felony dui conviction holding that the mailing of a certified copy of a remand order to a state court divests federal jurisdiction holding that for sentencing purposes the government does not need to allege a defendants prior conviction or prove the fact of a prior conviction where that fact is not an element of the present crime