Whether expert evidence based on or involving handwriting analysis is sufficiently reliable to satisfy the requirements of Federal Rule of Evidence 702 or comparable State rules for the admissibility of expert evidence

United States v. Brothers Construction Company of Ohio, Inc., 219 F.3d 300, 310-311 (4th Cir. 2000) (upholding trial court's admission of the grand jury testimony of co-defendant Tri-State's officer as an admission by party's agent because (1) "[a]t the time....A statement by an agent or an employee who is not authorized to speak on behalf of the agent's principal or the employee's employer may nonetheless be treated as the statement of the principal or the employer and thus as a vicarious admission that is exempt from the prohibition against hearsay; but such a statement can be imputed to the principal or the employer only if the statement, if by an agent, is about a matter within the scope of the agent's agency or, if by an employee, the statement is about a matter within the scope of the employee's employment.

United States v. Maliszewski, 161 F.3d 992, 1009 (6th Cir. 1998) (upholding trial court's admission of the Mireles testimony [about defendant's repeated statements made by her dead husband] because at the time of the trial,....For purposes of the hearsay exceptions created by Federal Rule of Evidence 804 or a comparable State rule a declarant is "unavailable" within the meaning of Rule 804(b) or a comparable State rule if the declarant is unable to be present or to testify at the hearing because of death or then existing physical or mental illness or infirmity; but a declarant is not "unavailable" if the declarant's absence is due to the procurement or wrongdoing of the proponent of a statement for the purpose of preventing the witness from attending or testifying.

United States v. Daly, 716 F.2d 1499, 1510 (9th Cir. 1983) (upholding trial court's admission of co-defendant's testimony "that she and Criswell went to [accused's] car lot, where she received a car known by Criswell and Ginger to be stolen"where it constituted as circumstantial evidence of accused Daly's...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.