California, United States of America
The following excerpt is from Patel v. Shiomoto, A136228 (Cal. App. 2013):
evidence showing the report was made at or near the time of the reported event" rendered it inadmissible hearsay under section 1280. (Downer v. Zolin, supra, 34 Cal.App.4th at p. 582.) In dictum, and as relevant here, the court went on to state that "a report prepared nearly a week after the forensic tests were completed does not fall within the statutory requirement that the report be prepared 'at or near the time' of the reported event." (Id. at p. 582, fn. 5.)
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