the statement] is to establish or prove past events potentially relevant to later criminal prosecution.” 547 U.S. at 822, 126 S.Ct. 2266. This primary purpose is discerned according to a “reasonable participant” standard and is “ascertained from the individuals’ statements and actions and the circumstances in which the encounter occurred.” Michigan v. Bryant, — U.S. -, 131 S.Ct. 1143, 1156, 179 L.Ed.2d 93 (2011) (acknowledging that although there may be mixed motives, the primary purpose controls the testimonial inquiry). By this measure, the accusatory statements the police elicited from Ms. Parker are testimonial; indeed, they cannot be materially distinguished from those deemed testimonial in Hammon v. Indiana, the companion case to Davis. See Davis, 547 U.S. at 830, 126 S.Ct. 2266 (<HOLDING>). The police were dispatched to the Frye-Parker
holding that plaintiffs motion to amend her complaint to add her husband as a defendant did not relate back because her failure to sue her husband was not due to misnomer or mistake involving the identity of the proper party but because the law at the time of the complaint did not allow one spouse to sue another in tort holding that ms hammons statements were testimonial where they were the product of an interrogation  conducted in a separate room away from her husband  with the officer receiving her replies for use in his investigacion  holding that parts of the adult sexual assault victims statement to emergency room personnel that described the nature of the alleged attack and the cause of her symptoms and pain were not testimonial because they fell into the category of statements made by a patient with a selfish interest in treatment and were not accusatory in nature internal quotation marks and citation omitted holding a wife liable for necessary medical expenses incurred by her husband under the doctrine even though the wife did not sign as a guarantor and did not request that her husband be admitted nor anticipate that her husband would be admitted recognizing the crawford interrogation was more formal but determining the interrogation of hammons wife was formal enough in considering that factor and determining the wifes statements were testimonial