The following excerpt is from People v. Brown, 517 N.E.2d 515, 522 N.Y.S.2d 837, 70 N.Y.2d 513 (N.Y. 1987):
The imposition of an arbitrary time limit would run counter to the assumptions underlying the admissibility of excited utterances and would contravene our recent decisions which have departed from the rigid res gestae analysis, with its requirement of contemporaneity, in favor of admitting excited utterances, as exceptions to the hearsay rule, on the basis of their inherent trustworthiness. Moreover, in recognizing that excited utterances made after the event may be admitted if "not made under the impetus of studied reflection" (People v. Edwards, supra, at 497, 419 N.Y.S.2d 45, 392 N.E.2d 1229), we have necessarily acknowledged that the psychological and emotional effect of the sudden event may persist and continue to operate with undiminished force for a period of time thereafter. How long such effect may persist depends on many factors, including the nature of the initial trauma or shock and the subsequent activities of the declarant (see, id., at 497, 419 N.Y.S.2d 45, 392 N.E.2d 1229).
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