Second, a joint trial prevents the delay associated with separate, successive trials, thus serving the interests of "both the government and the accused."

To come within Rule 801 (d)(1)(B), the prior consistent statement need not be proffered through the testimony of the declarant but may be proffered through any witness who has first-hand knowledge of the statement.

Nevertheless, in a case decided before, and referred to in Maultasch, the court permitted the introduction of a prior consistent statement though a third party witness.

The government also correctly identified "misnomers or typographical errors" as the frequent and appropriate subject of prosecutorial and judicial amendments.(See id

Thus, they have declined to enforce the requirement that the declarant be subject to cross-examination concerning the statement.

As is to be expected, in determining admissibility trial courts are afforded a good deal of latitude in weighing, in light of the totality of the circum-stances, the corroborative value of the prior consistent statement and trial concerns

When a court upheld consistent rulings one way, a dissenter called for "a closer scrutiny of the record."

—government had to prove extorted illegal payments in order to establish income that had gone unreported

Furthermore, a single trial will eliminate the delay occasioned by separate trials, serving the interests of the public, the government, and the defendants in a speedy trial.

[CITATION] Winning at the NLRB