What is the test for establishing a hearsay exception in a civil case?

"As a condition precedent to challenging the exclusion of proffered testimony, Evidence Code section 354, subdivision (a), requires the proponent make known to the court the 'substance, purpose, and relevance of the excluded evidence . . . .' This requirement applies equally to establishing a hearsay exception." (People v. Ramos (1997) 15 Cal.4th 1133, 1178.) Having failed to ask for admission of the court records under Evidence Code section 452.5, defendant cannot fault the trial court for failing to grant it. (Ibid.) We agree with the Attorney General that this contention was forfeited.⁶

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