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

Cf. United States v. Petrie, 302 F.3d 1280, 1287-1288 (11th Cir. 2002) (upholding trial court's exclusion of business records of B&L Securities [prepared by its secretary] because "the trustworthiness prong of Rule 803(6)....The hearsay exception for "business records" created by Federal Rule of Evidence 803(6) or a comparable State rule applies only (i) the record is based on the personal knowledge of an entrant with a business duty to record the event or other such matter or (ii) if the record of the event is based on the personal knowledge of a person who had a business duty to transmit the information about the event or other matter to the person or persons who made the record and had a business duty to do so. A person has a "business duty" if the person has a duty to an organization by reason of law, contract, employment relationship, or other such matter to record or report an event, condition, opinion, or other matter to which the business records exception to the hearsay rule may apply.

United States v. Harris, 331 F.2d 185, 188 (4th Cir. 1964) (reversing conviction for possession of nontaxpaid whiskey and ordering new trial because even though during direct examination defendant had admitted prior convictions for dealing in nontaxpaid whiskey, the trial court erred in admitting evidence...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.

United States v. McHorse, 179 F.3d 889, 902 (10th Cir. 1999) (upholding the trial court's ruling which allowed the prosecutor's inquiry on cross-examination of accused and his son on specific incidents involving his daughter and half-sister because their testimony of accused's character or pertinent trait...Although a character witness who testifies to the reputation of another person or gives an opinion of the character of another person cannot testify to specific instances of that person's conduct to bolster the character witness's testimony, an opposing party may question the character witness about specific instances of the person's conduct to show that the character witness' testimony about the character of the person was not well-founded.