A statement by a co-conspirator of a party is not barred by the hearsay rule from being admitted against the party if the statement was made by the co-conspirator during the course and in furtherance of the conspiracy.

Fed. R. Evid. 803(18) ("To the extent called to the attention of an expert witness upon cross-examination or relied upon by the expert witness in direct examination, statements contained in published treatises, periodicals, or pamphlets on a subject of history, medicine, or other science or art, established as a reliable authority by the...If a treatise, periodical, or similar literature is shown to be reliable and authoritative on a topic, under some circumstances a statement in such literature about the topic falls within an exception to the prohibition against the admission of hearsay evidence.

Chambers v. Mississippi, 410 U.S. 284, pin? (1973).The right to due process guaranteed by the Fifth and Fourteenth Amendments prohibits the exclusion of probative exculpatory evidence in criminal trials when exclusion of such evidence is unreasonable, arbitrary, or disproportionate.

United States v. McIntosh, 200 F.3d 1168, 1169 (8th Cir. 2000) (upholding trial court's admission of certified court documents [which misidentified defendant's 1995 state felony possession conviction] as public records....An exception to the hearsay rule applies to the following records of government offices and agencies: (A) public records that set forth the activities of the government office or agency; (B) public records that set forth observations that a government office or agency was required to make and report but this exception does not apply in criminal cases to observations of police officers and other law enforcement personnel; or (C) in civil actions and proceedings and in criminal cases when offered against the government, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate the untrustworthiness of such findings.