People v. Maldonado

Defendant adequately preserved objection to repeated references to gang activity as improper evidence of motive, by filing written reply brief in response to State's motion in limine to allow gang references, for limited purpose of explaining why witnesses recanted and by objecting in written postconviction petition. Exception to allow evidence of prior consistent statement where recent fabrication is alleged applies only to prior consistent statements made after alleged motive to fabricate arose. Introduction of more than one statement inconsistent with a witness's trial testimony is proper, regardless of whether such statements are consistent with each other.