Brown v. Epps, 686 F.3d 281, 286 (5th Cir. 2012) (emphasis added). See also Keaton v. State, 375 So.3d 44, 115 (Ala.Crim.App.2021) (noting that the admission of "'nontestimonial evidence'" does "not violate the defendant's right to confrontation" (quoting Craft v. State, 90 So.3d 197, 216 (Ala.Crim.App.2011))); and United States v. Watson, 525 F.3d 583, 588-89 (7th Cir. 2008) ("The Confrontation Clause does not ... apply to statements that are not testimonial in nature."). Whether the hearsay statements contained within a document are testimonial in nature hinges on whether the document was "created solely for an 'evidentiary purpose,'" Bullcoming v. New Mexico, 564 U.S. 647, 664 (2011) (quoting Melendez-Diaz v. Massachusetts, 557 U.S. 305, 311 (2009)), i.e., whether its "primary purpose" was to serve as "an out-ofcourt substitute for trial testimony," Michigan v. Bryant, 562 U.S. 344, 358 (2011)), designed "to establish or prove some fact at trial."