Task: Text Completion
Input (English): v. Crapps, 64 Mass. App. Ct. 915, 916 (2005). First, Commonwealth v. Verde, 444 Mass. 279, 280 (2005), held that “a drag certificate is akin to a business record and the confrontation clause is not implicated by this type of evidence.” We ruled that a docket sheet, like a drug certificate, is a business record and thus does not trigger the confrontation clause. Commonwealth v. Crapps, supra. Second, we determined that a docket sheet was not testimonial “because authors of prior conviction records are not witnesses against criminal defendants.” Id. at 916 n.3, citing People v. Shreck, 107 P.3d 1048, 1060-1061 (Colo. Ct. App. 2004) (docket sheets are business records that are explicitly exempt from the Crawford standard). See Commonwealth v. Maloney, 447 Mass. 577, 591-592 (2006) (<HOLDING>). In June, 2009, the United States Supreme 
 Holding statements: (A) holding that g l c 278  11 a allowing record of conviction to serve as prima facie evidence of prior conviction did not violate confrontation clause (B) holding that doctrine does not violate right of confrontation (C) holding appellate court erred in reversing conviction on confrontation clause grounds because appellant did not clearly articulate to trial court that confrontation clause demanded admission of evidence in question (D) holding prior statement subject to crossexamination when made does not violate confrontation clause (E) holding that hearsay argument for admission of evidence did not preserve confrontation clause challenge on appeal argument could have referred either to rules of evidence or confrontation clause but failed to identify confrontation clause as basis and thus did not put trial court on notice of issue
Output (English): (A)