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Bailey Junior Kurariki was further remanded in custody in Manukau District Court on Wednesday morning while a judge considers a bail application.
The country's youngest convicted killer was arrested on March 29 on a charge of assaulting Janie Martin, believed to be his girlfriend.
Kurariki's lawyer Jeremy Sutton asked for bail until the case was heard, saying Kurariki had already been in custody for five weeks.
But Judge Sami Epati told Kurariki his decision might not be favourable and he had already received a "final warning".
He remanded Kurariki in custody until May 11, when he will hand down his decision.
Kurariki was 12 when he was involved in the killing of pizza delivery man Michael Choy in 2001.
He was jailed for seven years for Choy's manslaughter and released in May 2008.
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