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Name: People v. Coon
Case #: D052722
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 04/23/2009
Subsequent History: rev. granted 8/12/09 (S173359)
Summary

Faxed copies of certified court records were admissible under secondary evidence rule. Coon appealed his conviction for multiple substance abuse and weapons offenses, contending that the trial court prejudicially erred in admitting faxed copies of certified court records to establish that he was on bail when he committed the offenses. The faxed documents were certified copies of the records, but what was admitted was a fax copy of the certified copies, not the original. The appellate court found no error and affirmed. There was no genuine dispute concerning authenticity of the documents. Both the transmit terminal identification header and the contents of the document support a determination the documents were, in fact, records from the Riverside County file. Since the faxed documents were admissible under the secondary evidence rule and there was sufficient evidence to authenticate them, the trial court did not err by admitting them.