changes to M.R.E.s 103(a)(2), 404(a), 701-702, and 803(6) that have already taken effect through operation of M.R.E. 1102. 3 . The First, Third, Fifth, Seventh, and D.C. Circuits follow rules similar to the Ninth Circuit’s formulation in Cox. See, e.g., United States v. Saccoccia, 58 F.3d 754 (1st Cir.1995); United States v. Dicker, 853 F.2d 1103, 1108-09 (3d Cir.1988); United States v. White, 569 F.2d 263, 267 (5th Cir.1978); United States v. Marzano, 537 F.2d 257, 268 (7th Cir.1976); DeLoach v. United States, 307 F.2d 653, 655 (D.C.Cir.1962) (pre-Federal Rules of Evidence case); see also United States v. Coleman, 284 F.3d 892, 894 (8th Cir.2002) (upholding police officer's testimony interpreting defendant’s "drug jargon”); United States v. Peoples, 250 F.3d 630, 640-42 (8th Cir.2001) (<HOLDING>). The Sixth Circuit, however, maintains that a
recognizing that although early interpretations of the act were narrow subsequent interpretations demonstrate that the act reaches a wide variety of deceptive commercial practices holding that fbi agents testimony regarding witnesss pri or identification was admissible where nothing in the record suggested that the declarant was unavailable for reexamination after the agents testimony holding that an fbi agents investigation of the written contents of a notebook that was lawfully in the possession of the fbi constituted a search that violated the defendants fourth amendment rights holding that the plaintiffs ftca claims failed because the fbi agents were privileged to use reasonable force under texas law holding that fbi agents interpretations of codefendants conversations were inadmissible under fedrevid 701