California, United States of America
The following excerpt is from The People v. John Paul Nelson, D057195, D057198, No. BAF003133 (Cal. App. 2010):
10. The spontaneous statement exception to the hearsay rule does not require a showing that the declarant is unavailable to testify at trial. (People v. Anthony O. (1992) 5 Cal.App.4th 428, 436.)
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