Can a defendant rely on a probation report that states that a defendant was convicted of a federal criminal offence and confronted by a police officer?

Defendant's hearsay and confrontation claims have no merit. Although the probation report's statements regarding defendant's federal conviction were hearsay, a probation officer's report of a defendant's prior convictions is a conventional substitute for live testimony. Probation reports are considered to be inherently reliable. (People v. Evans (1983) 141 Cal.App.3d 1019, 1021.) Trial courts routinely receive and rely upon such hearsay in making sentencing decisions based upon probation reports. Defendant argues that the report was unreliable because it "involved an alleged prosecution by the

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