If a communication between husband and wife was made during the marriage and is protected by the confidential marital communications privilege, termination of the marriage by death or divorce does not extinguish the protection of the privilege for such communications made during the marriage.

United States v. Adefehinti, 510 F.3d 319, 326-327 (D.C. Cir. 2007) (upholding trial court's admission of hundreds of loan applications, sales contracts, promissory notes, verifications of deposit, verifications of employment....Federal Rule of Evidence 902(11) provides for self-authentication for the original or a duplicate of a domestic business record that satisfies the admissibility requirements ofFederal Rule of Evidence 803(6) if the record is accompanied by a written declaration of its custodian or other qualified person, in a manner complying with any federal statute or any rule prescribed by the Supreme Court pursuant to statutory authority, certifying that the record (A) was made at or near the time of the occurrence of the matters set forth by, or from information transmitted by, a person with knowledge of those matters; (B) was kept in the course of the regularly conducted activity; and (C) was made by the regularly conducted activity as a regular practice.

Millennium Partners, L.P. v. Colmar Storage, LLC, 494 F.3d 1293, 1302-1303 (11th Cir. 2007) (holding, in plaintiff brokers' negligence action, that evidence of repairs made by a tenant [who leased the warehouse after defendant vacated it] was properly....The rule limiting the admissibility of subsequent remedial measures does not apply to remedial measures by non-parties.

Cotter v. McKinney, 309 F.2d 447, 450-451 (7th Cir. 1962) (holding, in plantiff injured passenger's action against defendant driver for personal injury, that "the evidence as to the happening of the accident in the....The rule against the use of evidence about liability insurance on the issue of negligence or wrongful conduct applies to evidence about the insurance status of plaintiffs and claimants as well as the insurance status of defendants and alleged wrongdoers.