Howard was an employee of the Veteran's Administration. She received her checks by mail, but one particular check never arrived. This check was later found in Stone's (D) possession. The government (P) introduced a progress sheet as evidence, with an accompanying affidavit to show that the check had been mailed. D's counsel objected due to extraneous and explanatory statements that were also in the affidavit. D was overruled. D was convicted and appealed, raising hearsay and confrontation issues.

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