Analysis of the case law in this area leads us to conclude that Flores' written statement was admissible for rehabilitative purposes under this exception. In People v. Powell, 53 Ill.2d 465, 469 (1973), the witness in question was a codefendant in whose automobile the murder weapon had been found. After cross-examination about a plea agreement that the witness had made in July 1969, the State introduced a prior statement of the witness, given in March 1969.

The first part of the defendants' two-part argument on this issue concerns the well-settled rule that a consistent statement is admissible to rebut a charge of recent fabrication. ( People v. Powell (1973), 53 Ill.2d 465, 474-75.) The defendants urge here that because Rodriguez' motive to fabricate predated his grand jury testimony, this testimony was inadmissible for purposes of rehabilitation.

Defendant properly recognizes that while a prior consistent statement is generally inadmissible to bolster the testimony of a witness, a prior consistent statement is admissible to rebut a charge of recent fabrication when the statement was made prior to the time the motive to fabricate arose. ( People v. Powell (1973), 53 Ill.2d 465, 474-75; People v. Tidwell (1980), 88 Ill. App.3d 808, 810-11; People v. Rosario (1979), 74 Ill. App.3d 607, 612.) Defendant argues that at the time Harrison made the statement he had a motive to fabricate and implicate defendant in order to obtain lenient treatment and that the plea agreement which was eventually reached was merely the fulfillment of Harrison's motivation to testify falsely.

Keene notes the absence here of circumstances such as would justify the use of such statements. See People v. Powell (1973), 53 Ill.2d 465, 474-75. The State contends, and we agree, that no basis exists to reach the merits of the issue.

However, in oral argument defense counsel seemed to urge that explanations could not be required of defense counsel. Our earlier decisions (see, e.g., People v. Davis (1983), 95 Ill.2d 1; People v. King (1973), 54 Ill.2d 291; People v. Powell (1973), 53 Ill.2d 465; People v. Butler (1970), 46 Ill.2d 162; People v. Harris (1959), 17 Ill.2d 446) consistently rejected claims that minority group members had been improperly excluded from the convicting juries. The opinions in those cases, however, did not specifically consider Taylor v. Louisiana, the Supreme Court decision which defendant here urges modified the earlier holding in Swain v. Alabama (1965), 380 U.S. 202, 13 L.Ed.2d 759, 85 S.Ct. 824.

( People v. Clark (1972), 52 Ill.2d 374, 288 N.E.2d 363.) An exception to this rule, however, applies when it is implied that a witness' testimony is recently fabricated, or that the witness had some motive to testify falsely. Under such circumstances, a prior consistent statement may be admitted if that statement was made before the motive to fabricate arose. ( People v. Powell (1973), 53 Ill.2d 465, 292 N.E.2d 409.) Thus, proof that the witness gave a similar account of the occurrence when the motive to lie was nonexistent or before the effect of the account could be foreseen makes the prior consistent statement admissible. ( Powell, 53 Ill.2d 465, 292 N.E.2d 409.) Furthermore, when a witness has been impeached by proof that he has made prior inconsistent statements, he may bring out all of the prior statements to qualify or explain the inconsistency and rehabilitate the witness.

People v. Hudson (1980), 86 Ill. App.3d 335, 340, 408 N.E.2d 325. • 12 Evidence of a statement made by a witness out of court but harmonizing with his testimony is inadmissible except where he is charged with recent fabrication or his opponent raises an inference that he has a motive to testify falsely. ( People v. Powell (1973), 53 Ill.2d 465, 474-75, 292 N.E.2d 409.) Whether Leon Moore's prior consistent statement was admissible in this case depends upon the degree to which his cross-examination by defense counsel can be characterized as a charge of recent fabrication or improper motive.

Accord, People v. Attaway (1976), 41 Ill. App.3d 837, 852, 354 N.E.2d 448; and People v. Thornhill (1975), 31 Ill. App.3d 779, 783, 333 N.E.2d 8.) In People v. Powell (1973), 53 Ill.2d 465, 478, 292 N.E.2d 409, the court held that the exercise of peremptory challenges removing five prospective black jurors and leaving one failed to constitute a prima facie case of purposeful discrimination. 53 Ill.2d 465, 478.

It is undisputed that Brown's testimony concerning Bush's alleged prior statements was inadmissible as substantive evidence to prove the truth of the facts asserted therein. (See People v. Collins (1971), 49 Ill.2d 179, 198, 274 N.E.2d 77; People v. Powell (1973), 53 Ill.2d 465, 472, 292 N.E.2d 409.) However, the defendant contends that Brown's testimony was admissible as impeaching evidence offered to show Bush's bias toward the defendant.

However, in the instant case, defendant contends that no proper foundation was laid by the prosecution for the introduction of the alleged prior inconsistent statement of defendant. In support defendant cites and strongly relies upon the holdings in People v. Moses (1957), 11 Ill.2d 84, 142 N.E.2d 1; People v. Henry (1970), 47 Ill.2d 312, 265 N.E.2d 876; People v. Rodgers (1972), 53 Ill.2d 207, 290 N.E.2d 251; and People v. Powell (1973), 53 Ill.2d 465, 292 N.E.2d 409. The cases are consistent in the statement of the general rule: "Before prior inconsistent statements are offered for impeachment purposes, a foundation must be laid when the witness, whose credibility is challenged, is cross-examined. [Citation.] This rule is designed to protect the witness from unfair surprise and assure him the opportunity to deny or to explain the prior statement.