Alexander

Following a series of robberies in August and September 2012, a San Francisco police officer reviewed police reports of the crimes and surveillance video of eight of them before arresting defendants and *568 appellants Bryan Alexander and Ray Farr. 1 Alexander and Farr subsequently pled guilty to several of the offenses. In the published portion of this opinion we reject appellants' contention the trial court erred in denying their motion to suppress evidence discovered pursuant to their warrantless arrest. We conclude, among other things, the trial court properly admitted the officer's testimony that the videos helped provide probable cause for appellants' arrest. We reject appellants' arguments this testimony constituted hearsay, relied on unauthenticated writings and violated the secondary evidence rule. Further, we determine the information possessed by the officer was sufficiently reliable to justify the arrest. In the unpublished part of this opinion, we reject appellants' claim the trial court erred in calculating conduct credits, and we remand to the trial court to exercise its discretion regarding whether to strike a five-year sentence enhancement imposed on Alexander…

I concur with the majority opinion, except to the extent it remands the matter for Alexander to be resentenced pursuant to Senate Bill 1393 (SB 1393). (Sen. Bill No. 1393 (2017-2018 Reg. Sess.) § 667.) That issue is not properly before us, because Alexander did not obtain a certificate of probable cause.

It is fundamental that an appellant who challenges the validity of his or her plea must first obtain a certificate of probable cause from the trial court. ( People v. Panizzon (1996) 13 Cal.4th 68 , 76, 51 Cal.Rptr.2d 851 , 913 P.2d 1061 ; Pen. Code, § 1237.5.) Where the appellant seeks to change a sentence that the parties had agreed would be imposed as part of the plea bargain, the appellant is in substance challenging the plea's validity and a certificate of probable cause is required. (E.g., Panizzon, supra , 13 Cal.4th at p. 78 , 51 Cal.Rptr.2d 851 , 913 P.2d 1061 ; People v. Cuevas (2008) 44 Cal.4th 374 , 381-382, 79 Cal.Rptr.3d 303 , 187 P.3d 30 .)

Here, Alexander's plea was part of an agreement by which the court would impose, and did impose, a specific sentence of 14 years, including five years for his prior conviction of attempted robbery ( Pen. Code, § 667, subd.…