People v. Denson

Defendant was convicted, after jury trial, of first-degree murder, armed robbery, and home invasion. Statements of what happened and what led to predicament of coconspirators was not mere narrative, but furthered the efforts to conceal their actions. Thus, statements were admissible under coconspirator exception to hearsay rule, and are admissible against all coconspirators where declaration was made during pendency of and in furtherance of conspiracy. Defendant raised issue of quality of witness' memory of events, which was outside of impeachment of witness with her prior inconsistent statement. (ZENOFF and SCHOSTOK, concurring.)