California, United States of America
The following excerpt is from People v. Cervantes, B292142 (Cal. App. 2019):
of recording the witness'[s] statement at the time it was made; [] (3) [i]s offered after the witness testifies that the statement he made was a true statement of such fact; and [] (4) [i]s offered after the writing is authenticated as an accurate record of the statement." (Evid. Code, 1237, subd. (a).) We apply "the abuse of discretion standard of review to any ruling by a trial court on the admissibility of evidence, including one that turns on the hearsay nature of the evidence in question [citations]." (People v. Waidla (2000) 22 Cal.4th 690, 725.)
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