What is the test for admitting evidence of hearsay in a civil case?

adverse party has no opportunity to cross-examine the declarant, and the [trier of fact] cannot observe the declarant's demeanor while making the statements.' " (People v. Duarte (2000) 24 Cal.4th 603, 610.)

Nonetheless, "[e]vidence of a statement by a declarant . . . is not made inadmissible by the hearsay rule if the declarant is unavailable as a witness and the statement, when made, . . . created such a risk of making [the declarant] an object of hatred, ridicule, or social disgrace in the community, that a reasonable [person] in [the declarant's] position would not have made the statement unless [the person] believed it to be true." (Evid. Code, 1230.) For this exception to apply, the proponent of the evidence must show: (1) the declarant was unavailable, (2) the declarant's statement was against the declarant's social interest, and (3) the statement was sufficiently reliable to warrant admission despite its hearsay character. (People v. Duarte, supra, 24 Cal.4th at pp. 610-611.)