When will a court allow appellant to authenticate a form in his own defense?

Having considered the record at hand, we find the trial court's error in not allowing appellant to authenticate the form was harmless because it is not reasonably probable a result more favorable to defendant would have occurred absent the error. (People v. Watson (1956) 46 Cal.2d 818, 836.) The trial court ruled that the form would not be admitted into evidence but placed no limits on appellant's testimony. Appellant testified in his own defense and explained why he cut up the car into pieces. Appellant testified that he was unable to obtain "[t]he original owner's signature on some other paperwork" in order to get a junk slip required by the recycling center. Appellant stated he did not have that paperwork because it was not his intention "to transfer the vehicle." Furthermore, overwhelming evidence supported appellant's guilt. Appellant possessed a car that had been reported stolen just days before. He admitted he sold the car to the recycling center but was unable to produce any paperwork showing ownership. Appellant searched unsuccessfully for documentation related to the stolen vehicle but did not disclose he possessed the current registration for the vehicle until it was discovered in his shirt pocket during the booking process. Moreover, had appellant introduced the form into evidence, the prosecution's attack on its authenticity would have weakened appellant's defense. Appellant did not disclose the existence of the form during discovery and waited until he was about to testify; the information related to Sanchez could not be verified; the driver's license number was false and a non-working telephone number was listed; and Sanchez was unavailable to testify.

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