Federal Rule of Evidence of Evidence 804(b)(3) or a comparable State rule creates a hearsay exception for a statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.

United States v. Hines, 717 F.2d 1481, 1491 (4th Cir. 1983) (upholding trial court's admission into evidence of the recorded voice because there was evidence "sufficient to establish [the defendant's] identity as the....Federal Rule of Evidence 901(b)(6) and comparable State rules provide that a statement made by a person over the telephone may be authenticated (i) if the call was to a person, the call was to the number assigned to the person and circumstances, including self-identification, show or suggest that the person who spoke was the person who was called and (ii) if the call was to a business, the call was to the number assigned to that business and the conversation related to business reasonably transacted over the telephone.

United States v. Hagege, 437 F.3d 943, 958 (9th Cir. 2006) (upholding trial court's admission into evidence of the foreign business records which did not violate defendant's Confrontation Clause rights because "the....no

United States v. Ettinger, 344 F.3d 1149, 1160-1161 (11th Cir. 2003) (upholding trial court's admission of officer Barnes' statement contained in the FBI report because "the FBI report was admissible as a prior consistent....A prior statement of a witness is exempt from the prohibition against hearsay evidence if the prior statement is consistent with the witness' testimony at the trial or hearing at which the prior statement is offered, the prior statement is offered to rebut a express or implied charge of recent fabrication or motive, and the witness who made the prior statement testifies and is subject to cross-examination at the trial or hearing at which the prior statement is offered.