A statement can be hearsay if the statement that is offered in evidence was made at any time other than at the hearing or trial in which it is offered in evidence.

United States v. Floyd, 343 F.3d 363, 368 (5th Cir. 2003) (upholding trial court's admission into evidence of the staged Houston and Los Angeles accidents because there was sufficient evidence to show that the accidents involved the accused and that they were staged).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.

United States v. McCulley, 178 F.3d 872, 876 (7th Cir. 1999) (upholding trial court's exclusion of portion of defendant's adopted, written statement about incorrect bearings used in starter generators as inadmissible....A "statement" for purposes of the hearsay prohibition against the admission of hearsay statements is (1) an oral or written assertion or (2) nonverbal conduct of a person, if it is intended by the person as an assertion.

United States v. Diaz, 961 F.2d 1417, 1419-1420 (9th Cir. 1992) (affirming conviction for possession with intent to distribute cocaine, holding that "accused's propensity to commit crimes is an admissible character trait ... accused's propensity to engage in large scale drug dealing, however, is not an...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.