With no explanation, chose the best option from "A", "B", "C" or "D". 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

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 prior statement subject to crossexamination when made does not violate confrontation clause
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 that doctrine does not violate right of confrontation
A.