California, United States of America
The following excerpt is from People v. McDonough, F074675 (Cal. App. 2019):
As the parties both note, to be admissible such a statement must be made "before there has been time to contrive and misrepresent, i.e., while the nervous excitement may be supposed still to dominate and the reflective powers to be yet in abeyance." (People v. Washington (1969) 71 Cal.2d 1170, 1176.) Extended periods of time do not discount the spontaneity of the relevant statement, provided there is evidence the statement was provided under the continuing stress of the event. (See People v. Trimble (1992) 5 Cal.App.4th 1225, 1234-1235 [considering nearly two-day lapse of time before statement].)
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