A hearsay statement can be either oral or written.

United States v. Hassouneh, 199 F.3d 175, 182-183 (4th Cir. 2000) (reversing conviction and remanding for new trial because the trial court, when accused attempted to present relevant evidence that his false statements were made in jest, erred in prohibiting testimony of accused's reputation for jocularity).A criminal defendant may offer a pertinent trait of his or her character circumstantially -- to show the defendant's doing or non-doing of a specific act.

Cf. United States v. Gwathney, 465 F.3d 1133, 1140-1142 (10th Cir. 2006) (holding that the trial court erroneously admitted Western Union's response to the DEA's subpoena as a business record exception because the proper foundation....There is a hearsay exception for a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses, made at or near the time by, or from information transmitted by, a person with knowledge, if kept in the course of a regularly conducted activity of a business, institution, association, profession, occupation, or calling if it was the regular practice of that business, institution, association, profession, occupation, or calling to make the memorandum, report, record or data compilation, unless the source of information or the method or circumstances of preparation indicate lack of trustworthiness.

Cf. United States v. Pirovolos, 844 F.2d 415, 422-423 (7th Cir. 1988) (upholding trial court's ruling which allowed government's questions on the presence of other weapons at accused's restaurant; held, "when accused chose to rely on self-defense as an affirmative defense, he placed his intent in...If a criminal defendant offers evidence of his or her character circumstantially - to show he or she did not commit the crime charged -- the prosecution can offer rebutting evidence of defendant's character.