What is the test for establishing that there is evidence of a conspiracy?

" 'Once independent proof of a conspiracy has been shown, three preliminary facts must be established: "(1) that the declarant was participating in a conspiracy at the time of the declaration; (2) that the declaration was in furtherance of the objective of that conspiracy; and (3) that at the time of the declaration the party against whom the evidence is offered was participating or would later participate in the conspiracy." ' " (People v. Homick (2012) 55 Cal.4th 816, 871.)

In California, the existence of the conspiracy must be established by evidence independent of the proffered statement. (People v. Herrera, supra, 83 Cal.App.4th at

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