The Sixth Amendment Confrontation Clause places no limits on the admission at trial of nonhearsay statements made prior to or outside of trial.

United States v. Conroy, 424 F.3d 833, 839-840 (8th Cir. 2005) (upholding trial court's admission of victim Tail's prior consistent statements to a police officer because "[w]hile the statements admitted to rehabilitate....A prior consistent statement is admissible to prove the truth of the matter asserted by the prior consistent statement only if the prior consistent statement is admissible to rebut a charge of recent fabrication or motive to fabricate.

Jaffee v. Redmond, 518 U.S. 1, pin? (1996) (psychotherapist-patient or therapist-patient privilege was recognized or created by the Supreme Court and held applicable in a federal civil action for wrongful death against a police officer; question of applicability of the...There is a psychotherapist-patient privilege.

United States v. Williams, 506 F.3d 151, 155 (2d Cir. 2007) (upholding trial court's admission of co-defendant Bobby's out-of-court statements as statements against penal interest because (1) statements were....Federal Rule of Evidence of Evidence 804(b)(3) or a comparable State rule creates a hearsay exception for a statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.