this exception unless the proponent demonstrates an express original agreement among the conspirators to continue to act in concert in order to cover up, for their own self-protection, traces of the crime after its commission. Grunewald v. United States, 353 U.S. 391, 404, 77 S.Ct. 963, 973, 1 L.Ed.2d 931, 943 (1957). It is also well settled that secrecy plus overt acts of concealment do not establish an express agreement to act in concert in order to conceal the crime. Grunewald, 353 U.S. at 403, 77 S.Ct. at 973, 1 L.Ed.2d at 942. Admission of hearsay statements on this basis would impermissibly expand the narrow scope of the co-conspirator exception and further dilute the general prohibition against hearsay statements. See Krulewitch, 336 U.S. at 444, 69 S.Ct. at 718, 93 L.Ed. at 794 (<HOLDING>). As the United States Supreme Court
holding that statements by a cooperating coconspirator to known authorities made after the commencement of cooperation are not admissible under rule 801d2e because such statements are not made in furtherance of the conspiracy holding that statements made to keep a coconspirator informed as to the groups drug supply were made in furtherance of the conspiracy holding that the conspiracy theory of personal jurisdiction requires that the outofstate coconspirator was or should have been aware of the acts performed in the forum state in furtherance of the conspiracy holding that the confrontation clause of the sixth amendment is not violated by the admission of hearsay statements under the coconspirator exception to the hearsay rule where the defendant was able to confront and crossexamine the witness who claimed that the statements at issue were made holding that statements aimed at preventing detection and punishment were not admissible under the coconspirator exception because admission of such statements would expand exception to hearsay rule to include declarations made not in furtherance of conspiracy charged but made in furtherance of an alleged implied but uncharged conspiracy aimed at preventing detection and punishment