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. Patterson, 277 F.3d 709, 713 (4th Cir. 2002) (upholding trial court's admission into evidence of the laser-generated images of defendant's fingerprints because "an adequate foundation was provided,....Federal Rule of Evidence 901(b)(4) and comparable State rules allow a thing or matter to be authenticated by its distinctive characteristics considered in conjunction with circumstances.

United States v. Archer, 843 F.2d 1019, 1023 (7th Cir. 1988) (upholding trial court's ruling which allowed the government to introduce evidence of accused's involvement in prior escape plans where it demonstrated that accused "had a profound awareness of security measures and various escape methods and...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.

Cf. United States v. Jones, 299 F.3d 103, 112-113 (2d Cir. 2002) (upholding trial court's admission of the testimony of Officer Moreland because "Chin's requirement that the [trial] court consider 'the....The right of confrontation guaranteed by the Sixth Amendment to the Constitution of the United States bars the introduction against a criminal defendant of testimonial hearsay by a nontestifying declarant unless (i) the absent declarant is unavailable to testify at trial and (ii) the defendant had an adequate opportunity to cross-examine the absent declarant prior to trial.