State v. Vessichio
In State v. Vessichio, 197 Conn. 644, 654-55, 500 A.2d 1311 (1985), cert. denied, 475 U.S. 1122 (1986), the Court held that before coconspirator statements may be admitted as an exception to the hearsay rule, the court must make a preliminary determination, by a preponderance of the evidence, that there is sufficient independent evidence to establish:
(1) that a conspiracy existed;
(2) that the conspiracy was still in existence at the time the statements were made;
(3) that the declarations were made in furtherance of the conspiracy;
(4) that the declarant and the defendant participated in the conspiracy.