What is the case law on hearsay under the Venner doctrine?

[27] Any increase in their value or weight under the Ares v. Venner doctrine would depend on a cautious search for circumstances that would tend to guarantee the trustworthiness of the hearsay and for circumstances that would suggest a practical necessity for a departure from the accepted standards of fairness that allow an opposing party to challenge and test allegations, perceptions and opinions by way of cross-examination.