What must be proved beyond a reasonable doubt in a civil case?

13 This caution appears appropriate since at least one court has apparently confused what must be proved with the degree of persuasion. See United States v. Mandel, 408 F.Supp. at 682-83.

14 The above observation must be no more than hyperbole. As will be seen in section III-D, infra, it may be that the district court in Long had no more than hearsay before it. Although hearsay may bear sufficient indicia of reliability under certain circumstances to support a finding (see Calhoun v. Bailar, 626 F.2d 145 (9th Cir. 1980), cert. denied, 452 U.S. 906, 101 S.Ct. 3033, 69 L.Ed.2d 407 (1981), I can hardly believe that anybody would be convinced beyond a reasonable doubt by mere hearsay.