The Unavailable Declarant

An example taken from Professor Gold's scintillating Evidence 2 handout:

Action for divorce. To prove adultery by husband, Donald Trump, Wife offers statement of Paris Hilton, a permanent resident of a psychiatric hospital in Europe, made during an interview for America's Most Disgusting Celebrities: "I got drunk and had an affair with Trump." Admissible?

Answer:
In the federal system- No, because although the declarant is unavailable, the statement is not a declaration against her financial or penal interest.

In the California system- Yes, because the declarant is unavailable and the statement is against her social interest.

Perfect timing.... justice has been served and Paris Hilton is once again UNAVAILABLE