A crime or wrong similar to the crime or wrong at issue in the trial has been held, said, or assumed to be relevant under the circumstances of the case.

Fed. R. Evid. 801(d)(2)(E) ("a statement by a coconspirator of a party during the course and in furtherance of the conspiracy").A statement falls within the hearsay exemption for statements of co-conspirators only if the statement was made in furtherance of the conspiracy.

United States v. Bradley, 390 F.3d 145, 154-155 (1st Cir. 2004) (upholding trial court's admission into evidence of accused's prior abusive treatment of other workers because "the intimidation of [the other workers] was part of a pattern of intimidation that carried over to [the complaining workers].").Other wrongs or crimes that show an unusual pattern of conduct by a person are not barred by the prohibition against the use of character or disposition to show conduct on a particular occasion.

Cf. United States v. Jackson, 335 F.3d 170, 179 (2d Cir. 2003) (upholding trial court's exclusion of Brown's plea allocution as residual hearsay exception because the statements "lacked corroborating circumstances....A statement not specifically covered by Federal Rule of Evidence 803 or 804 or by comparable State rules, but having equivalent circumstantial guarantees of trustworthiness, is not excluded by the hearsay rule, if the court determines that (A) the statement is offered as evidence of a material fact; (B) the statement is more probative on the point for which it is offered than any other evidence which the proponent can procure through reasonable efforts; and (C) the general purposes of these rules and the interests of justice will best be served by admission of the statement into evidence.