in his concurring opinion in Crawford when he said “To its credit, the Court’s analysis of ‘testimony’ excludes at least some hearsay exceptions, such as business records and official records. See Ante at 56 [124 S.Ct. 1354].” By way of background, in United States v. Figueroa, an unpublished opinion appearing at 2000 WL 963346 (10th Cir.2000) which predated Crawford, we spoke as follows: FN5. Figueroa suggests in his brief that the warrant of deportation or removal which stated that an INS agent had witnessed the deportation in 1997 was not sufficient evidence that he had been deported in 1997. Other courts have found that this warrant is admissible in trial as proof that a defendant was arrested and deported. See United States v. Quezada, 754 F.2d 1190, 1193-94 (5th Cir.1985) (<HOLDING>); United States v. Hernandez-Rojas, 617 F.2d
holding that warrant of deportation is admissible hearsay under fed revid 8038b to prove defendant was deported holding that fulltime forensic chemists employed by texas department of public safety were lawenforcement personnel whose reports were not admissible under publicrecord hearsay exception rule 8038b or businessrecord hearsay exception rule 8036 holding that an internal investigative report which included multiple hearsay statements based on interviews with employees was admissible as a party admission under 801d2d concluding that 801d2d does not require anything else along the lines of internal verification of the reports contents but ruling that the report could have been properly excluded under fed revid 403 for lack of trustworthiness based on the absence of any factual content in the hearsay statements holding exception set forth in rule 8038b was inapplicable to warrant of deportation where notation that alien was deported was ministerial objective observation with inherent reliability because of the governments need to keep accurate records of the movement of aliens holding that fulltime forensic chemists employed by texas department of public safety were lawenforcement personnel whose reports were not admissible under either the publicrecord hearsay exception rule 8038b or the businessrecord hearsay exception rule 8036