California, United States of America
The following excerpt is from People v. Mejia, G049509 (Cal. App. 2015):
presents 'independent evidence to establish prima facie the existence of . . . [a] conspiracy[,]'" and also substantiates "three preliminary facts . . .: '(1) that the declarant was participating in a conspiracy at the time of the declaration; (2) that the declaration was in furtherance of the objective of that conspiracy; and (3) that at the time of the declaration the party against whom the evidence is offered was participating or would later participate in the conspiracy.'" (People v. Hardy (1992) 2 Cal.4th 86, 139.)
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