The following excerpt is from U.S. v. Heal, 972 F.2d 1345 (9th Cir. 1992):
To determine whether a conspiracy exists, a court may consider the coconspirator's statements themselves. Bourjaily v. United States, 483 U.S. 171, 181 (1987). In addition, there must be independent evidence of the conspiracy and the defendant's involvement in it for the court to conclude that a conspiracy existed. United States v. Silverman, 861 F.2d 571, 577 (9th Cir.1988).
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