U.S. v. Sepulveda, No. 92-1362 (1st Cir.) (15 F.3d 1161) (December 20, 1993) (Judge Bruce M. Selya)
In this case, the Court also held that a co-conspirator's statement "standing alone, is insufficient to meet the preponderance standard of Rule 801(d)(2)(E). . . . [A]dmitting the statement into evidence requires some extrinsic proof of the declarant's involvement in the conspiracy.".
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