Oftentimes in the Washington DC domestic violence assault cases, the complainant does not actually testify for one reason or another. In such cases, the government attempts to introduce the 911 reporting/call of the complainant in lieu of the substantive evidence of assault. If the 911 tape recoding does meet the three prong test for admission; then the recording can and will be admitted and relied upon by the trier of the facts albeit the jury or the judge. The DC Court of Appeals on August 17, 2017, in Pelzer v. U.S., highlighted and outlined the test of admissibility for the
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