The following excerpt is from United States v. Clevenger, CASE NO. 11-cr-3518 - IEG (S.D. Cal. 2011):
To be made "in furtherance of" the conspiracy, "a statement must advance a common objective of the conspiracy or set in motion a transaction that is an integral part of the conspiracy." United States v. Williams, 989 F.2d 1061, 1068 (9th Cir. 1993). "Although mere conversations or narrative declarations between coconspirators are not in themselves sufficient to invoke the exception to the hearsay rule, statements made to keep coconspirators abreast of an ongoing conspiracy's activities satisfy the 'in furtherance of' requirement." Id. Moreover, it is not necessary that the statements be made to another member of the conspiracy. Id.
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