government to play parts of the recording for the jury. Foster argues that the recording and transcript were inadmissible hearsay and that their admission violated his Sixth Amendment right to confrontation because Williams did not testify at trial. We analyze each declarant’s statement separately for the purposes of hearsay analysis. See United States v. Tolliver, 454 F.3d 660, 665-66 (7th Cir.2006). Under Rule 801(d)(1)(B), an out-of-court statement is excluded from the hearsay rule if (1) that statement is consistent with the declarant’s trial testimony; (2) the party offering that statement did so to rebut an express or implied charge of recent fabrication or improper motive against the declarant; (3) that statement was made before the declarant had a motive for fabri 6th Cir.1980) (<HOLDING>). Anderson’s prior consistent statement was not
holding witnesss prior consistent statement admissible where defense counsel implied in his opening statement that witness should not be believed because of the favorable consideration he received from the government in his plea bargaining agreement holding that the prosecutors statement about a witnesss truthfulness was proper because the evidence showed that the witness complied with the plea agreement not that he told the truth simply because he entered into the plea agreement holding that government could not impeach witness with prior statement because he refused to answer any questions and thus gave no testimony in court with which the prior statement could be judged to be inconsistent holding that trial counsel was not ineffective when he failed to introduce defendants prior consistent statement statement was not admissible because it was made after defendant had been arrested clearly not a time when the effect of the statement could not have been foreseen holding witnesss prior consistent statement admissible in part because defense counsel implied during opening statement that witness had fabricated her testimony