PEOPLE v. SINGH


47 A.D.3d 733 (2008)

849 N.Y.S.2d 606

THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. TEJPAL SINGH, Appellant.

Appellate Division of the Supreme Court of the State of New York, Second Department.

Decided January 15, 2008.


Ordered that the judgment is affirmed.

In order for a declaration against penal interest to be admissible at trial, the proponent must establish that (1) the declarant was unavailable as a witness at trial; (2) the declarant was aware that the statement was adverse to his or her penal interest when made; (3) the declarant had competent knowledge of the facts underlying the statement; and (4) "most important, supporting circumstances...

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