What is the test for establishing that statements by a victim about the value of a stolen property constitute "prima facie evidence of value for purposes of restitution"?

California, United States of America


The following excerpt is from People v. Pando, G051834 (Cal. App. 2016):

"[I]t is well settled that 'statements by the victims of the crimes about the value of the property stolen constitute "prima facie evidence of value for purposes of restitution." [Citations.]'" (People v. Prosser (2007) 157 Cal.App.4th 682, 690.) "Were the law otherwise, a victim in a case such as this would be without a means for recovery. A victim who has no receipts or appraisals for property received by gift, and who no longer has possession of the property, may have no way of providing a detailed description or obtaining an appraisal. . . . If the thief has disposed of the property and is,

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