In In re Emilye A. (1992) 9 Cal.App.4th 1695, a father appealed a juvenile court dependency order based on the allegation that he had sexually molested his adopted daughter. ( Id. at p. 1699.) At issue was the admission of the mother's testimony that her daughter stated that "daddy" had given her an "owie," pointing to her vaginal area. The declarant child was two years and eleven months old at the time. ( Id. at p. 1700.) The court held that the statement qualified under the "spontaneous statement exception" to the hearsay rule: "Although minor's remarks were not made until a day or two after she received her 'owie,' the circumstances under which they were made are sufficient to qualify them as spontaneous declarations." ( Id. at p. 1713.) One of those circumstances that the court found significant was that the statements "were made by a child sufficiently young that her reflective powers would be relatively unsophisticated . . . ." (Ibid.)