To be admitted as an "excited utterance," most courts require a showing that "at the time of the statement the declarant was under the stress of excitement caused by an external event sufficient to still her reflective faculties and had no opportunity for deliberation

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The rule for admitting an "excited utterance" into evidence typically requires that the statement was made while the speaker was still under the stress of excitement from an event, which would limit their ability to reflect or fabricate, ensuring the spontaneity and sincerity of the statement.

To Be Admitted as an "Excited Utterance," Most Courts Require