The following excerpt is from U.S. v. Dendy, 995 F.2d 233 (9th Cir. 1993):
We review a district court's conclusion that statements were made in furtherance of a conspiracy for clear error. United States v. Nazemian, 948 F.2d 522, 529 (9th Cir.1991), cert. denied, 113 S.Ct. 107 (1992). It is not necessary that a particular statement in fact furthered the objectives of the conspiracy; the relevant inquiry is whether the declarant intended the statement to further the conspiracy. United States v. Schmit, 881 F.2d 608, 612 (9th Cir.1989); Nazemian, 948 F.2d at 529. Statements which are admissible as in furtherance of a conspiracy include "statements made to keep co-conspirators abreast of an ongoing conspiracy's activities." Nazemian, 948 F.2d at 529; see also United States v. Anderson, 813 F.2d 1450, 1456 (9th Cir.1987).
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