People v. Ramos

After joint jury trial, Defendant was convicted of armed robbery with a firearm. Court erred in admitting detective’s testimony as to historical cell site analysis (HCSA) evidence. This was inadmissible hearsay and was prejudicial. That detective used Google Earth to convert raw coordinate data from T-Mobile report into comprehensible format did not change its character as hearsay. Court’s blanket prohibition against defense counsel using trial transcript, on which he had written notes to assist with his closing argument, was an abuse of discretion, as court was effectively barring defense counsel from using his own notes. (HOFFMAN and CUNNINGHAM, concurring.)