What is the test for making a declaration of intent against a party to a party in a criminal conspiracy?

MultiRegion, United States of America

The following excerpt is from U.S. v. Wiley, 519 F.2d 1348 (2nd Cir. 1975):

The relevant textual portion of United States v. Nixon, 418 U.S. 683, 94 S.Ct. 3090, 41 L.Ed.2d 1039 (1974), states that "Declarations by one defendant may also be admissible against other defendants upon a sufficient showing, by independent evidence, of a conspiracy among one or more other defendants and the declarant and if the declarations at issue were in furtherance of that conspiracy."

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