The following excerpt is from U.S. v. Valdez-Soto, 31 F.3d 1467 (9th Cir. 1994):
5 As we've previously stated, this requirement is "simply a further emphasis upon the showing of necessity and reliability and a caution that the hearsay rule should not be lightly disregarded...." United States v. Friedman, 593 F.2d 109, 119 (9th Cir.1979).
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