a co-defendant creates a Confrontation Clause problem. Therefore, evidence admitted under Rule 806 in a criminal case should be admitted only for the limited purpose of impeachment. 10 . See Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). 11 . At trial, Huerstel claimed he was not involved in the shootings, rather that he lied to the police about his involvement because he feared what Prasertphong might do to him or his family if he told anyone Prasertphong was involved in the murders. Huerstel also claimed the police threatened him and made promises of leniency during his interrogation. 12 . Nor is a request for a parent considered the functional equivalent of a request for counsel. See Fare v. Michael C. 442 U.S. 707, 724, 99 S.Ct. 2560, 61 L.Ed.2d 197 (1979) (<HOLDING>). 13 . The trial court chastised the officers
holding that juveniles request to call parent is assertion of fifth amendment privilege against selfincrimination holding a juveniles request to speak to a probation officer is not a per se invocation of fifth amendment rights holding that per se statutory rule is not permissible under fourth amendment holding that juveniles request for parent is invocation of fifth amendment rights holding that an unequivocal invocation of the fifth amendment right to counsel must be presented in a manner that a reasonable police officer under similar circumstances would understand the statement to be a request for the presence of an attorney