In People v. Falletto (202 N.Y. 494 [1911]), the Court reiterated its concern with the use of dying declarations. Writing that the exception is based on a "public necessity" (id. at 500), and that the absolute requirements are clear proof of the certainty of speedy death and that the declarant has no hope of recovery (id.), the Court concluded: "Dying declarations are dangerous, because made with no fear of prosecution for perjury and without the test of cross-examination, which is the best method known to bring out the full and exact truth. The fear of punishment after death is not now regarded as so strong a safeguard against falsehood as it was when the rule admitting such declarations was first laid down. Such evidence is the mere statement of what was said by a person not under oath, usually made when the body is in pain, the mind agitated and the memory shaken by the certainty of impending death. A clear, full and exact statement of the facts cannot be expected under such circumstances, especially if the declaration is made in response to suggestive questions, or those calling for the answer of 'Yes' or 'No.' Experience shows that dying declarations are not always true." (Id. at 499.)