error unless it “seriously affect[s] the fairness, integrity, or public reputation of the judicial proceedings.” Id. at 777 (citations omitted). The district court did not plainly err in admitting the testimony of Robinson. In short, under Rule 701, Robinson had sufficient first-hand knowledge of the conversation with Wantuch and Jurgita, that was based on his direct participation, as well as his perception and observation of Wan-tuch. The jurors were presented with the entire video-recorded conversation between Robinson and Wantuch on December 13, 1999. Robinson specifically told Wantuch’s clients to lie on the INS forms, and he observed Wantuch assist him in coaching his clients to make false representations. See United States v. Estrada, 39 F.3d 772, 773 (7th Cir.1994) (per curiam) (<HOLDING>); United States v. Lizardo, 445 F.3d 73, 83
holding that a witness may testify about his subjective interpretation of a conversation in which he is participating as long as his opinion is rationally based on his perception and is helpful either to an understanding of his testimony or to the determination of a fact in issue holding that in order to state a claim for ineffective assistance of counsel based on the failure to call a witness to testify the claimant must allege 1 the identity of the potential witness 2 that the witness was available to testify at trial 3 the substance of the witnesss testimony and 4 an explanation of how the omission of the testimony prejudiced the case holding that a statement taken in violation of the prophylactic rule  that once defendant invokes his sixth amendment right to counsel subsequent waiver of that right is presumed invalid if secured pursuant to policeinitiated conversation  may be used to impeach defendants inconsistent testimony holding district court erred in admitting a witnesss responses to the governments questions about six fiftyfive and five dollar where the appeals court could not tell whether the witnesss interpretations were based on his exper tise or a conversation with the informant holding that a participant in a conversation may testify as to his understanding of the conversation to satisfy rule 701as requirement that the testimony be rationally based on the witnesss perceptions