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  • To admit hearsay testimony under Rule 801(d)(2)(E), the district court ???must find (a) that there was a conspiracy, (b) that its members included the declarant and the party against whom the statement is offered [ (the ???non-offering party???) ], and (c) that the statement was made during the course of and in furtherance of the conspiracy.??? United States v. Alameh, 341 F.3d 167, 176 (2d Cir.20
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