In the defendant's murder trial, the trial court properly admitted out-of-court statements made by the defendant's girlfriend to her friend asking the friend to lie and say she had borrowed the gun that was the murder weapon, intending to create an alibi for the girlfriend and the defendant. The girlfriend's statements were admissible under the co-conspirator exception to the hearsay rule [T.R.Evid. 801(e)(2)(E)] to advance an ongoing conspiracy to hinder the defendant's apprehension rather than statements that were made after the underlying conspiracy to commit murder had been carried out. Guevara v. State - 04-07-00027-CR.