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See MCI Communications v. American Tel. & Tel. Co., 708 F.2d 1081 (7th Cir. 1983) (affirming trial court's admission of an internal study made by senior officers of defendant, manifesting an intent to obstruct competition in violation of antitrust law) cert. denied 464 U.S. 891, 104 S. Ct. 234, 78 L. Ed. 2d 226 (1983). 

Weinstein's discussion of Rule 801(d)(2)(D) (Weinstein's Evidence § 801(d)(2) (D)(01), p. 801-137), states that: Rule 801(d)(2)(D) adopts the approach . . . which, as a general proposition, makes statement made by agents within the scope of their employment admissible . . . . Once agency, and the making of the statement while the relationship continues, are established, the statement is exempt from the hearsay rule so long as it relates to a matter within the scope of the agency.

After reciting a lengthy quotation which justifies the rule as necessary, and suggests that such admissions are trustworthy and reliable, Weinstein states categorically that although an express requirement of personal knowledge on the part of the declarant of the facts underlying his statement is not written into the rule, it should be. He feels that is mandated by Rules 805 ...

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