In People v. Towery (1985) 174 Cal.App.3d 1114, the defendant was one of six codefendants charged with conspiracy to commit thefts of fuel oil. The defendant was convicted of two counts of grand theft but found not guilty for conspiracy. On appeal, the defendant argued the trial court erred in ruling admissible recorded telephone conversations with a codefendant, Conroy, who recorded conversations with defendant without defendant's knowledge. (Towery, supra, 174 Cal.App.3d at pp. 1123-1124.) The Towery court held the recorded conversations were properly admitted. The court noted none of the defendants disputed "the well-established rule that a tape recording of a conversation between a criminal defendant and a third party made with the voluntary consent of the third party is admissible in a criminal proceeding." (Towery, supra, 174 Cal.App.3d at p. 1124.) The Towery court next rejected the contention the recorded conversations should have been excluded pursuant to section 632, subdivision (d). The court determined the law enforcement exception under section 633 applied even though Conroy used his home telephone and personal tape recorder to record the conversations, which occurred without a police officer present when a recording was made. (Towery, supra, 174 Cal.App.3d at pp. 1126-1127.) The court noted it was reasonable to permit Conroy to make the recordings at home versus the police station because a sudden change in the telephone number might create suspicion. (Id. at p. 1129.) The Towery court observed a law enforcement officer provided Conroy with the tapes to use, which Conroy turned in to law enforcement on a regular basis, "usually within a day of recording and never more than three days from the time the tape was completed." (Towery, supra, 174 Cal.App.3d at p. 1127.) Law enforcement directed Conroy "to record all telephone calls dealing with the subject matter of stolen oil, and Conroy testified that he recorded most of the telephone conversations he received pertinent to the ongoing investigation." (Ibid.) The Towery court held the "looseness of law enforcement direction" was an issue of weight and not initial admissibility of the tapes. (Id. at p. 1129.) The court finished its analysis noting "no counsel was precluded at trial from questioning Conroy or the law enforcement officer about the manner in which the tapes were made, nor were they precluded from arguing to the jury that Conroy, with his significant motivation in cooperating with the police, might have altered the tapes to further his own interest." (Id. at p. 1129.)