Temistocles Paulino (defendant) was convicted of charges involving drugs. Paulino was arrested in an apartment at 70 Peace Street. The apartment was part of a drug operation, and Paulino was arrested after an informant bought cocaine from the apartment and police observed Paulino peering out the window during the transaction. When the police searched the apartment, Paulino was in the kitchen, and Paulino had the only key to the apartment on his person. During the search, a receipt for a money order was found with Paulino’s name on it. The receipt said Paulino’s address was 70 Peace Street, and it stated that payment was made to Tower Management for $580 for May rent. The government used this receipt as evidence that Paulino paid rent for the apartment while the drug operation was conducted out of it. Following his conviction, Paulino appealed, arguing in part that the money-order receipt was hearsay.