A duplicate of a writing is sometimes admissible to the same extent as an original writing to prove the contents of an original writing, but this exception for a duplicate is inapplicable if the trial court finds that it would be unfair to allow the use of a duplicate in lieu of the original.

Cf. United States v. Kelley, 446 F.3d 688, 692-693 (7th Cir. 2006) (holding, in defendant's appeal from the revocation of his supervised release, that the trial court properly admitted the witnesses' hearsay statements because....The federal constitutional guarantee of due process may limit the government's right to introduce unreliable hearsay evidence against a defendant in a criminal trial.

United States v. Hunt, 521 F.3d 636, 643 (6th Cir. 2008) (upholding trial court's refusal to admit the statements from an affidavit under Rule 804(b)(1) because "[defendant] has not demonstrated that the Government....The hearsay exception for prior testimony applies in a criminal case only if the if the party against whom the testimony is now offered had an opportunity and similar motive to develop the testimony in the prior proceeding by direct, cross, or redirect examination. The exception applies in a civil action or proceeding only if the party against whom the testimony is now offered or a predecessor in interest had an opportunity and similar motive in the prior proceeding to develop the testimony by direct, cross, or redirect examination.

United States v. Wright, 343 F.3d 849, 867 (6th Cir. 2003) (upholding trial court's admission of taped conversations because "these conversations were in furtherance of the conspiracy as charged and not just 'idle....A statement falls within the hearsay exemption for statements of co-conspirators only if the statement was made in furtherance of the conspiracy.