California, United States of America
The following excerpt is from People v. Power, F075750 (Cal. App. 2019):
"[A] hearsay statement, even if otherwise spontaneous, is admissible only if it relates to an event the declarant perceived personally." (People v. Phillips (2000) 22 Cal.4th 226, 235.) " 'The foundation for this exception is that if the declarations are made under the immediate influence of the occurrence to which they relate, they are deemed sufficiently trustworthy to be presented to the jury. [Citation.]' " (People v. Poggi (1988) 45 Cal.3d 306, 318.)
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