If a statement is to fall within the hearsay exception for present sense impressions created by Federal Rule of Evidence 803(1) or a comparable State rule, the maker of the statement -- the declarant -- must personally perceive the event or condition that he or she describes or explains with the statement.

United States v. Bell, 516 F.3d 432, 441 (6th Cir. 2008) (reversing convictions for possession of marijuana and cocaine base with intent to distribute and remanding for new trial because, even though the trial court correctly concluded that there was sufficient evidence to show that accused had committed...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. Hernandez, 105 F.3d 1330, 1332 (9th Cir. 1997) (upholding trial court's admission of defendant's statement to border patrol agent about the location of his birth because under Rule 804(b)(4)(A), it is....If the declarant is unavailable, Federal Rule of Evidence 804(b)(4) or a comparable State rules recognizes a hearsay exception for (A) A statement concerning the declarant's own birth, adoption, marriage, divorce, legitimacy, relationship by blood, adoption, or marriage, ancestry, or other similar fact of personal or family history, even though declarant had no means of acquiring personal knowledge of the matter stated; or (B) a statement concerning the foregoing matters, and death also, of another person, if the declarant was related to the other by blood, adoption, or marriage or was so intimately associated with the other's family as to be likely to have accurate information concerning the matter declared.

United States v. Bobb, 471 F.3d 491, 499 (3d Cir. 2006) (upholding trial court's admission of the recorded out-of-court statements because they "were surreptitiously recorded and either were made by co-conspirators....The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.