Does a defendant have a right to a jury trial of the issue of authenticity, accuracy, or sufficiency of prior conviction records?

We see no reason to retreat from our conclusion in Kelii. It might be a rare case in which the question of authenticity, accuracy, or sufficiency of prior conviction records is seriously at issue, and depending on the circumstances, the question might well be for the court under the reasoning of Wiley and Kelii. Nevertheless, in an appropriate case, the defendant has a right under Penal Code sections 1025 and 1158 to a jury trial of those issues. Of course, the court would have to make a preliminary assessment of authenticity before admitting written documents into evidence (Evid.Code, 403, 1401), but this preliminary assessment would not preclude the jury from subsequently finding the documents inauthentic if the evidence in that regard was sufficiently persuasive. (See, e.g., DuBois v. Sparrow (1979) 92 Cal.App.3d 290, 296-297, 154 Cal.Rptr. 717; see also Evid.Code, 1400 [defining "[authentication of a writing" for purposes of admissibility into evidence].)