In People v. Houck (1998) 66 Cal.App.4th 350, the court found a preliminary hearing transcript to be inadmissible. According to Houck: "More recently, however, the Supreme Court has recognized that this technical definition of 'record of conviction' may not be appropriate and that the term may be defined 'more narrowly, as referring only to those record documents reliably reflecting the facts of the offense for which the defendant was convicted.' ( People v. Reed 1996, supra, 13 Cal.4th 217 at p. 223.) In Reed, the information alleged that the defendant had suffered two prior serious felony convictions, including one for assault with a deadly weapon or by means of force likely to produce great bodily injury, which conviction resulted from a guilty plea. The prosecution sought to establish that the assault conviction was a serious felony for Three Strikes purposes by producing the preliminary hearing transcript and a portion of the probation report. The appellate court determined that it was improper for the trial court to consider the probation report, but permissible to consider the transcript. The Supreme Court affirmed, holding that, in the context of a conviction resulting from a guilty plea, the preliminary hearing transcript was part of the record of the prior conviction, and thus admissible, in accordance with the analysis of People v. Guerrero, supra, 44 Cal.3d 343." (Houck, supra, 66 Cal.App.4th at pp. 355-356.) Houck then stated: "Considerations of reasonableness and fairness dictate that a 'record of conviction' include only those documents that reliably reflect the conduct of which a defendant was convicted. Because the prior conviction in this case resulted from a jury verdict, it is clear that the preliminary hearing transcript is not reliable as to what evidence was presented to, or relied on by, the jury in reaching its verdict. Further, the prosecution offers no explanation as to why use of this less reliable information is necessary or appropriate. Requiring that the prosecution produce evidence that was actually presented to the trier of fact is not unduly burdensome, promotes fairness and precludes the possibility that the underlying conduct will effectively be relitigated through the presentation of information that may not have been produced at trial. Because the preliminary hearing transcript is not necessarily an accurate reflection of what occurred at the trial, it is not part of the 'record of conviction' . . . ." (Houck, supra, 66 Cal.App.4th at pp. 356-357.) Houck continued: "The prosecution argues that the transcript should nonetheless be considered as part of the 'record of conviction' since Houck had ample opportunity to introduce evidence from the trial to establish that he did not use a deadly weapon in committing the crime. This argument is unavailing. Whether Houck could or should have introduced record evidence regarding the nature of the underlying crime is irrelevant to the issue of whether the prosecution may rely on a preliminary hearing transcript to establish the nature of a prior conviction when more reliable evidence (i.e., the trial transcript) is available for that purpose. In accordance with the 'reliable reflection' definition set forth in Reed, we hold that the preliminary hearing transcript was not part of the 'record of conviction' and thus was not admissible." (Houck, supra, 66 Cal.App.4th at p. 357.)