A subjective entrapment defense makes an accused's criminal liability contingent on a finding of the accused's predisposition or the accused's lack of predisposition to commit the crime charged and since criminal predisposition is a character trait, the defense of subjective entrapment makes accused's character an element of either a defense or a criminal charge, evidence of accused's criminal predisposition -- including evidence in the form of reputation, opinion, and evidence of specific instances of accused's conduct -- is not barred by the rule against the use of a person's character to show the person's conduct.

Williamson v. United States, 512 U.S. 594, pin? (1994).Federal Rule of Evidence of Evidence 804(b)(3) or a comparable State rule creates a hearsay exception for a statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.

United States v. Ramirez, 894 F.2d 565, 569 (2d Cir. 1990) (upholding trial court's admission of subsequent similar act evidence because it was significant and relevant in establishing accused's knowledge and state of mind at the time of his arrest in December 1987).Evidence of another crime, wrong, or act is admissible if there is sufficient evidence to support a finding by a reasonable juror that the other crime, wrong, or act occurred. Clear and convincing evidence is unnecessary; "sufficient" means only that there must be enough evidence to make the other crime, wrong, or act relevant.

Cf. United States v. Glenn, 312 F.3d 58, 67 (2d Cir. 2002) ("It is well-settled that flight can evidence consciousness of guilt. United States v. Salameh, 152 F.3d 88, 157 (2d Cir.1998) (per curiam). But the evidence at trial failed to prove flight.").Flight and escape from police officers, custody, prison, or government authorities has been held to be relevant under the circumstances when offered to show consciousness of, or belief in, criminal guilt.