What is the standard governing the admissibility of documentary evidence at a probation revocation hearing?

The standard governing the admissibility of documentary evidence at a probation revocation hearing depends on the type of evidence. Evidence submitted "as a substitute for the live testimony of an adverse witness at a revocation hearing" is inadmissible absent a showing of good cause. (People v. Arreola (1994) 7 Cal.4th 1144, 1156-1157, 1159 (Arreola).)² "[T]he need for confrontation is particularly important where the

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evidence is testimonial, because of the opportunity for observation of the witness's demeanor." (Id. at p. 1157.) In contrast, documentary evidence "that does not have, as its source, live testimony" is admissible if it is "sufficiently trustworthy to be relied upon by the trial court." (Id. at pp. 1156-1157.) "Generally, the witness's demeanor is not a significant factor in evaluating foundational testimony relating to the admission of evidence such as laboratory reports, invoices, or receipts, where often the purpose of this testimony simply is to authenticate the documentary material, and where the author, signator, or custodian of the document ordinarily would be unable to recall from actual memory information relating to the specific contents of the writing and would rely instead upon the record of his or her own action." (Id. at p. 1157.) We review the admission of hearsay evidence at a probation revocation hearing for abuse of discretion. (People v. Abrams (2007) 158 Cal.App.4th 396, 400.)