CALIFORNIA EVIDENCE: CIVIL AND CRIMINAL
...Hearsay Exceptions re Statements
......Co-Conspirator (Crim.) Admissions
.........Limit.: Must Show Prima Facie Conspir.
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Only prima facie evidence of a conspiracy is required to permit the trial court to admit evidence under the coconspirator's exception.

Under co-conspirator exception, need only establish prima facie evidence of conspiracy to admit evidence; conspiracy need not be charged.

Party offering evidence must prove by preponderance of evidence both preliminary facts of existence of conspiracy and D's involvement in it.

Prima facie evidence of conspiracy sufficient to allow co-D statements in under coconspirator exception.