The following excerpt is from U.S. v. Arreola-Armenta, 105 F.3d 667 (9th Cir. 1996):
"The use of transcripts as an aid in listening to tape recordings is reviewed for abuse of discretion." United States v. Armijo, 5 F.3d 1229, 1234 (9th Cir.1993). In reviewing whether tapes were properly admitted, this court looks to: (1) whether the court reviewed the accuracy of the transcript; (2) whether the defense was allowed to highlight alleged discrepancies and introduce alternative translations; (3) whether the defense was allowed to cross-examine the translator; and (4) whether a cautionary instruction was given. Id. However, these factors do not fully apply when the tape is not in English. Id. (holding that court need not review the transcript when tape was in Spanish).
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