California, United States of America
The following excerpt is from People v. White, G055134 (Cal. App. 2019):
send out. Despite the absence of names on the subject messages, the fact remains they were all sent from appellant's phone, and on the day in question, the phone traveled from the vicinity of appellant's house to the vicinity of the coin store. This is sufficient evidence to support the trial court's preliminary determination that appellant is the person who authored the incriminating messages that were found on his phone. (See generally People v. Valdez (2011) 201 Cal.App.4th 1429, 1435 [the foundation for the admissibility of a writing may be established by circumstantial evidence].)
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