California, United States of America
The following excerpt is from People v. Yoshimura, 154 Cal.Rptr. 314, 91 Cal.App.3d 609 (Cal. App. 1979):
This argument is valid only if the exhibits were "hearsay evidence," which is "evidence of a statement that was made other than by a witness while testifying at the hearing and that is offered to prove The truth of the matter stated." (Evid.Code, 1200, subd. (a) (italics added).) For purposes of this definition, the term " '(s)tatement' means (a) oral or written verbal expression or (b) nonverbal conduct of a person intended by him as a substitute for oral or written verbal expression." (Id., 225.) Some entries on the handwritten documents appear to qualify as "statements" within this definition. (See People v. Allen (1976) 65 Cal.App.3d 426, 433-434, 135 Cal.Rptr. 276.)
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