California, United States of America
The following excerpt is from People v. Warriner, D060686 (Cal. App. 2013):
"To be admissible as an exception to the hearsay rule, a prior consistent statement must be offered (1) after an inconsistent statement is admitted to attack the testifying witness's credibility, where the consistent statement was made before the inconsistent statement or (2) when there is an express or implied charge that the witness's testimony recently was fabricated or influenced by bias or improper motive, and the statement was made prior to the fabrication, bias, or improper motive." (People v. Riccardi (2012) 54 Cal.4th 758, 802.) The abuse of discretion standard applies to a trial court's ruling on the admissibility of evidence. (People v. Waidla (2000) 22 Cal.4th 690, 725.)
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