With no explanation, chose the best option from "A", "B", "C" or "D". 1, section 16, of the Florida Constitution guarantee criminal defendants the right to confront their accusers in a criminal trial. The primary interest secured by the confrontation clause is the defendant’s right of cross-examination. See Donaldson v. State, 722 So.2d 177, 186 (Fla.1998) (citing Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965)). I question whether this right is satisfied, at least under our state constitution, when the only evidence submitted by the state to establish the nature of a controlled substance in a drug case is information contained in a laboratory report prepared by a state employee at a police crime lab. But see United States v. Baker, 855 F.2d 1353 (8th Cir.1988), cert. denied, 490 U.S. 1069, 109 S.Ct. 2072, 104 L.Ed.2d 636 (1989) (<HOLDING>). Cf. United States v. Garnett, 122 F.3d 1016

A: holding that it did not violate the confrontation clause of the united states constitution to convict defendant for conspiracy to distribute controlled substance based upon a lab report admitted under the federal business records exception rule because this exception was firmly rooted
B: holding codefendants confession incriminating defendant was not within a firmly rooted exception to the hearsay rule under roberts standard
C: holding that the exception is not firmly rooted
D: holding that statements within a firmly rooted hearsay exception do not violate the confrontation clause
A.