What is the burden of establishing hearsay evidence?

The proponent of hearsay evidence has the burden of establishing the foundational requirements for its admissibility under an exception to the hearsay rule. (People v. Blacksher (2011) 52 Cal.4th 769, 819-820.) Where multiple levels of hearsay are involved, an exception must be shown at each level. (People v. Sanchez (2016) 63 Cal.4th 665, 675.) "[A] trial court has broad discretion to determine whether a party has established the foundational requirements for a hearsay exception [citation] and '[a]

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