California, United States of America
The following excerpt is from People v. Dozier, G049817 (Cal. App. 2014):
In the case People v. Cervantes (2004) 118 Cal.App.4th 162, 174, the court explained when it was not reasonably anticipated that a statement would be used at trial, the statement was not "testimonial" within the meaning of Crawford. Simply stated, the confrontation clause does not require exclusion of out-of-court statements that are not testimonial.
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