California, United States of America
The following excerpt is from People v. Sanchez, S087569 (Cal. 2019):
utterance must have been before there has been time to contrive and misrepresent, i.e., while the nervous excitement may be supposed still to dominate and the reflective powers to be yet in abeyance; and (3) the utterance must relate to the circumstances of the occurrence preceding it." ' " (People v. Lynch (2010) 50 Cal.4th 693, 751-752.)
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