it “rest[s] upon such solid foundations that admission of virtually any evidence within [it] comports with the ‘substance of constitutional protection.’ ” Roberts, 448 U.S. at 66, 100 S.Ct. 2531. For example, in United States v. Saks, 964 F.2d 1514 (5th Cir.1992), the Fifth Circuit identified several “firmly rooted” exceptions to the hearsay prohibition that would serve as exceptions to Bruton: the hearsay exception for co-conspirators in Rule 801(d)(2)(E), the “spontaneous declaration” exception in Rule 803(2), and the “medical examination” exception in Rule 803(4) of the Federal Rules of Evidence. See id. at 1525; White v. Illinois, 502 U.S. 346, 356, 112 S.Ct. 736, 116 L.Ed.2d 848 (1992); see also Bourjaily v. United States, 483 U.S. 171, 183, 107 S.Ct. 2775, 97 L.Ed.2d 144 (1987) (<HOLDING>); United States v. Shores, 33 F.3d 438, 442
holding that rule 8034 hearsay exception is firmly rooted for sixth amendment purposes holding codefendants confession incriminating defendant was not within a firmly rooted exception to the hearsay rule under roberts standard holding that no independent inquiry into reliability is required when the evidence falls within a firmly rooted hearsay exception like that for coconspirators under rule 801d2e internal quotation marks omitted holding that statements within a firmly rooted hearsay exception do not violate the confrontation clause holding that the exception is not firmly rooted