A man is charged with assaulting a woman who then died in Victoria.
Timothy O'Shannessy allegedly unlawfully assaulted, and intentionally and recklessly caused injury to, 39-year-old Michelle Norris in the Geelong suburb of Thomson on Sunday.
She died at the scene. Documents released by Geelong Magistrates Court on Tuesday show O'Shannessy, 42, is not charged directly with causing her death.
His lawyer told the court O'Shannessy did not want to be brought into court from his cell.
He remains in custody and is due back in court next Friday.