The following excerpt is from U.S. v. Clark, 67 F.3d 309 (9th Cir. 1995):
Hearsay evidence may be use in sentencing if there is "some minimal indicia of reliability." United States v. Huckins, 53 F.3d 276, 279 (9th Cir.1995). Statements against one's penal interest generally carry such indicia of reliability. See, e.g., United States v. Angulo-Lopez, 791 F.2d 1394, 1398 (9th Cir.1986).
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