face a situation in which the application of Foster’s approach would lead to a different result than application of Gray, the court of course should follow Supreme Court precedent. 12 . Since the United States Supreme Court decision in Gray, several circuit courts have interpreted Bruton-Richardson as modified by Gray, and determined that a court should only look to the face of extrajudicial statements by non-testifying co-defendant in discerning if the statement is expressly or inferentially incriminating. See, e.g., United States v. Akinkoye, 174 F.3d 451, 457 (4th Cir.1999) (finding no Bruton violation where the use of neutral phrases "another person” and "another individual” did not facially implicate the defendant); United States v. Vejar-Urias, 165 F.3d 337, 340 (5th Cir.1999) (<HOLDING>); United States v. Verduzco-Martinez, 186 F.3d
holding that the confession did not violate the confrontation clause because it was redacted to eliminate not only the defendants name but any reference to his or her existence holding that when all references to the defendant in a codefendants statement are replaced with indefinite pronouns or other general terms the confrontation clause is not violated by the redacted statements admission if when viewed together with other evidence the statement does not create an inevitable association with the defendant and a proper limiting instruction is given holding that when all references to the defendant in a eodefendants statement are replaced with indefinite pronouns or other general terms the confrontation clause is not violated by the redacted statements admission if when viewed together with other evidence the statement does not create an inevitable association with the defendant and a proper limiting instruction is given holding that the clause was not violated by a redacted confession with a proper limiting instruction holding that where a defendants name is replaced with a neutral pronoun as long as identification of the defendant is clear or inculpatory only by reference to evidence other than the redacted confession and a limiting instruction is given to the jury there is no bruton violation