According to the Advisory Committee’s notes, the wrongdoing does not have to be a criminal act, but it has to be improper in some way. Courts have interpreted the “wrongfully” language to mean “coercion, undue influence, or pressure to silence testimony and impede the truth-finding function of trials.”2 Merely persuading a witness to claim a privilege or forego testifying, therefore, does not fall within Rule 804(b)(6). But when persuasion becomes undue pressure, the party’s actions trigger the forfeiture exception. (Merritt 661).