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. Zedner, 401 F.3d 36, 49-50 (2d Cir. 2005) (upholding trial court's admission into evidence of rebuttal witnneses' testimony about accused's previous commission of fraud, where accused claimed lack of criminal intent, and evidence of fraud was relevant to prove accused's "financial...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.

Fed. R. Evid. 413(d) ("For purposes of this rule and Rule 415, "offense of sexual assault" means a crime under Federal law or the law of a State (as defined in section 513 of title 18, United States Code) that involved-- (1) any conduct proscribed by chapter 109A of title 18, United States Code; (2) contact, without consent, between any...Federal Rule of Evidence 413(d) provides that for purposes of Rule 413 and also for purposes of Federal Rule of Evidence 415 an "offense of sexual assault" is a crime under Federal law or the law of a State (as defined in section 513 of title 18, United States Code) that involved-- (1) any conduct proscribed by chapter 109A of title 18, United States Code; (2) contact, without consent, between any part of the defendant's body or an object and the genitals or anus of another person; (3) contact, without consent, between the genitals or anus of the defendant and any part of another person's body; (4) deriving sexual pleasure or gratification from the infliction of death, bodily injury, or physical pain on another person; or (5) an attempt or conspiracy to engage in conduct described in paragraphs (1)-(4).

Holmes v. South Carolina, 547 U.S. 319, pin? (2006).The right to due process guaranteed by the Fifth and Fourteenth Amendments prohibits the exclusion of probative exculpatory evidence in criminal trials when exclusion of such evidence is unreasonable, arbitrary, or disproportionate.