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.

Jaffee v. Redmond, 518 U.S. 1, pin? (1996) (psychotherapist-patient or therapist-patient privilege was recognized or created by the Supreme Court and held applicable in a federal civil action for wrongful death against a police officer; question of applicability of the...The therapist-patient or psychotherapist-patient privilege is applicable in civil actions.

United States v. Saget, 377 F.3d 223, 229-230 (2d Cir. 2004) (conviction for conspiracy to traffic in firearms and firearms trafficking; defendant contended that the district court violated his Confrontation Clause....The right of confrontation guaranteed by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution puts no constraints on the admissibility of nontestimonial hearsay statements; the federal constitutional right of confrontation does not apply to such statements.

United States v. Donaldson, 978 F.2d 381, 393-394 (7th Cir. 1992) (upholding trial court's amission of bank teller's videotaped deposition because she was properly determined as unavailable to testify at defendant's trial....For purposes of the hearsay exceptions created by Federal Rule of Evidence 804 or a comparable State rule a declarant is "unavailable" within the meaning of Rule 804(b) or a comparable State rule if the declarant is unable to be present or to testify at the hearing because of death or then existing physical or mental illness or infirmity; but a declarant is not "unavailable" if the declarant's absence is due to the procurement or wrongdoing of the proponent of a statement for the purpose of preventing the witness from attending or testifying.