Fed. R. Evid. 804(B)(3) Interpretation
In Trimble v. Stewart (Feb. 12, 1988), 11th Dist. No. 1327, 1988 Ohio App, a father sued his deceased daughter's estate for money that he asserted she was "holding" for him in her money market account.
The Court held that a statement made by the daughter prior to her death, indicating that the money was her father's, was a statement against interest pursuant to Evid.R. 804(B)(3) and, thus, admissible. Id. at 5.