801(d)(2)(E) the statement must be in furtherance of a conspiracy. Here, he's just telling his girlfriend, so whether he's refering to the robbery or not, it's not in furtherance of the ocnspiracy.
Here, assuming Ray knows of the robbery, it's in furtherance of the conspiracy. (But see (c))
(c): The paragraph after 801(d)(2)(E) states that the statement alone is not sufficient to establish the existence of a conspiracy or the participation therein of the declarant. So those things must be established by corroborating evidence, if it is to fit the hearsay exemption.