U.S. v. Green

In prosecution on mail and wire fraud charges stemming from scheme to submit bogus mortgage applications, Dist. Ct. did not err in admitting confession of non-testifying co-defendant that implicated defendant in charged offense where govt. substituted term "straw buyer" for defendant's name. Use of term "straw buyer" in said confession was not obvious reference to defendant even though jury could have concluded that defendant was "straw buyer" by comparing facts in confession to other properly admitted evidence. Dist. Ct. also did not commit prejudicial error in admitting business records under Rule 902(11) even though certificate from records custodian required under Rule 902(11) was signed by co-defendant, who had previously pleaded guilty to falsifying documents at issue in defendants' conspiracy, where record showed that many of subject records were duplicates of business records that had been admitted into record without objection.