about the statements. Townley, 472 F.3d at 1274; United States v. Gary, 999 F.2d 474, 479 (10th Cir.1993) (citing United States v. Wolf, 839 F.2d 1387, 1395-96 (10th Cir.1988)); see also Crawford v. Washington, 541 U.S. 36, 59 n. 9, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004) (“The [Confrontation] Clause does not bar admission of a statement so long as the declarant is present at trial to defend or explain it.”). Both Burnett and Medved testified and were cross-examined about the subjects of each of these statements, so even if they were admitted in error, their admission was harmless. III. Conclusion For the foregoing reasons, we AFFIRM Rutland’s convictions. 1 . Neither the defense nor prosecution asked for a James hearing. See United States v. James, 590 F.2d 575, 582 (5th Cir.1979) (<HOLDING>). 2 . During oral argument, Rutland's counsel
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 a trial court should not allow a jury to hear outofcourt coconspirator declarations before holding a hearing outside the jurys presence to determine whether such statements are admissible under federal rule of evidence 801d2e holding that post arrest statements made by coconspirator to law enforcement officer were not admissible under rule 801d2e but admission of testimony was harmless because officers testimony was cumulative holding statements by coconspirator nontestimonial and thus admissible holding that the confrontation clause does not require a showing of unavailability as a condition precedent to the admission of the outofcourt statements of a nontestifying coconspirator