A statement falls within the hearsay exemption for statements of co-conspirators only if the statement was made in furtherance of the conspiracy.

United States v. Morgan, 505 F.3d 332, 339 (5th Cir. 2007) (upholding trial court's admission of patient beneficiary records provided by Davies because "business records [were] not testimonial in nature....The right of confrontation guaranteed by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution puts no constraints on the admissibility of nontestimonial hearsay statements; the federal constitutional right of confrontation does not apply to such statements.

United States v. Goings, 313 F.3d 423, 426-427 (8th Cir. 2002) (conviction for theft and conspiracy to commit theft from an Indian tribal organization; accused argued that the district court erroneously excluded certain evidence about other employee loans and loan procedures; court affirmed conviction...During the cross-examination of a witness -- and during any examination of a witness who is a permissible target for impeachment -- the witness may be asked about specific acts that are indicative of the witness's untruthfulness if such acts are relevant to and probative of the witness' truthfulness or untruthfulness, unless the trial court determines that the acts inquired into are unduly prejudicial.

Fed. R. Evid. 609(d) ("Evidence of juvenile adjudications is generally not admissible under this rule," Federal Rule of Evidence 609.).Juvenile adjudications are generally inadmissible to impeach the truthfulness of a witness who has been adjudicated or convicted of a juvenile offense.