J

A proceeding to determine if an out-of-court statement of a co-conspirator should be admitted. The court looks to whether there was a conspiracy, if any of the parties were participating in the conspiracy, and if the statement was made in furtherance of the conspiracy. United States v. James, 590 F.2d 575 (5th Cir. 1979). See also Fed. R. Evid. 801(d)(2)(E).