California, United States of America
The following excerpt is from People v. Garcia, 210 Cal.Rptr.3d 88, 5 Cal.App.5th 640 (Cal. App. 2016):
Under federal constitutional law, such testimony is admissible if the prosecution shows it made a good-faith effort to obtain the presence of the witness at trial." (People v. Cromer (2001) 24 Cal.4th 889, 892, 103 Cal.Rptr.2d 23, 15 P.3d 243 ; see Crawford v. Washington (2004) 541 U.S. 36, 5354, 124 S.Ct. 1354, 158 L.Ed.2d 177.)
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