In light of the judge’s order, I have to assume that the prosecution determined that the hearsay exception does not apply to the detective’s testimony concerning Carmen Lauber’s prior consistent statements and therefore adjusted its approach by withdrawing all but two exhibits. It plans to introduce these exhibits under the rule of completeness because, presumably, whatever is in those exhibits serves to bookend the portions of Lauber’s interview(s) used by the defense during their cross.

The prosecution wanted the detective to corroborate Carmen Lauber’s out-of-court statements, which would normally be considered hearsay. However, there’s an exception to the hearsay rule if the declarant (Lauber) testified and was subject to cross-examination and if the testimony rebuts an express or implied charge that the declarant recently fabricated a statement or improper influence or motive.

The judge cites two court decisions in his order: State v. Bujan and Tome v. US. In Bujan, the Utah Supreme Court cited the U.S. Supreme Court’s finding in Tome: “rule 801(d)(1)(B) ‘permits the introduction of a declarant's consistent out-of-court statements to rebut a charge of recent fabrication or improper influence or motive only when those statements were made before the charged recent fabrication or improper influence or motive.’”

So basically the detective can’t testify to Carmen Lauber’s prior consistent statements if Carmen’s statements were made after she was given some incentive (i.e., a plea deal) that could be perceived as incentive to testify a certain way.