What is the burden of proving an itemized statement from a victim to a probation officer's investigation into lost or damaged property?

"Appellant renews in this court his contention that the victim's losses were insufficiently proven by her itemized statement. He relies on People v. Vournazos (1988) 198 Cal.App.3d 948, where the court held insufficient a statement from the victim itemizing stolen or damaged items with asserted values and repair costs. (Id. at p. 952, fn. 2.) The court held that this document failed to show that the claimed values represented replacement costs, or that the claimed repair costs reflected 'the actual cost of the repair.' (Id. at p. 958.)

"The Vournazos court professed to acknowledge the rule, adopted in an earlier case, that the defendant 'bears the burden of proving that the amount of restitution claimed by the victim exceeds repair or replacement cost of lost or damaged property.' (198 Cal.App.3d at p. 959, citing People v. Hartley (1984) 163 Cal.App.3d 126, 130.) In fact the Hartley decision stated an even broader rule: 'Since a defendant will learn of the amount of restitution recommended when he reviews the probation report prior to sentencing, the defendant bears the burden at the hearing of proving that amount exceeds the replacement or repair cost.' (163 Cal.App.3d at p. 130, italics added, fn. omitted.) The court went on to offer guidelines for the probation officer's 'inquiry or investigation' into the victim's losses. (Id. at p. 130, fn. 3.) However the decision appears to mean that, at least where the items, amounts, and sources are adequately identified in or with the probation report, the defendant has the burden of refuting them.