Does the rule against evidence of subsequent remedial measures apply only to a remedial measure that was taken after the event that caused a harm or injury? Is the rule inapplicable to a remedial measure that was taken after the alleged wrongdoer's defalcation but before any harm was done to the victim of the defalcation or wrong?

United States v. Rommy, 506 F.3d 108, 139-140 (2d Cir. 2007) (upholding trial court's admission of the statement of a Dutch police, a colleague of the detective who testified about the transcript which identified....The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.

United States v. Wright, 489 F.2d 1181, pin? (D.C. Cir. 1973) (prosecutor's comment in closing argument about demeanor of nontestifying criminal defendant).The courtroom behavior of nonwitnesses and events in the courtroom not arranged or introduced by trial counsel are not evidence even if such behavior or events occur in the presence of the trier of fact.

Cf. United States v. Curtin, 443 F.3d 1084, 1092-1093 (9th Cir. 2006) (reversing [in part] conviction for traveling with intent to engage in a sexual act with a minor and remanding for new trial because the trial court erred in admitting evidence of stories describing sexual activity with children...If another crime or wrong is offered under the second sentence of Federal Rule of Evidence 404(b) to show the identity of an actor, wrongdoer, or defendant (e.g., to show that a criminal defendant rather than someone else committed the crime for which defendant is on trial), the other crime or wrong and the act, wrong, or crime at issue at trial must have been committed in a distinctive as well as similar fashion.