California, United States of America
The following excerpt is from People v. Lee, C086770 (Cal. App. 2019):
Given defendant's charge that Asia's entire testimony lacked credibility and was unreliable, the People urge us to follow Brents, which stands for the proposition that where a defendant argues a witness's entire testimony is unreliable, the entirety of that witness's prior consistent statements are admissible to rehabilitate that witness. (People v. Brents (2012) 53 Cal.4th 599, 616.) This is not a case like Riccardi, where the prior consistent statement contains statements not made at trial or incidents not previously related to the jury. Indeed, Asia's prior statements pertained only to the events in question and covered topics elicited during her direct and cross-examination. Defendant does not allege, nor could we conclude, that testimony regarding Asia's prior statements
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added facts to Asia's testimony or character indictments of defendant as was the case in Riccardi.
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