A probation revocation hearing "is not part of a criminal prosecution and thus the full panoply of rights due a defendant in such a proceeding does not apply to probation revocations. " (Morrissey v. Brewer (1972) 408 U.S. 471.) "Revocation deprives an individual, not of the absolute liberty to which every citizen is entitled, but only of the conditional liberty properly dependent on observance of special parole or probation restrictions." (Ibid.) Even though Morrissey was a parole revocation case, the rule employed in that case applies to probation revocation equally. In Gagnon v. Scarpelli (1973) 411 U.S. 778, the probation of a defendant had been revoked without a hearing. (Id. at p. 780.) The United States Supreme Court concluded that probationers are also entitled to a probation revocation hearing and held that the same minimum requirements of due process applicable to parole revocations are applicable to probation revocations. (Id. at pp. 782, 791.) In Morrissey the United States Supreme Court pointed out that a revocation hearing should be "flexible enough to consider evidence including letters, affidavits, and other material that would not be admissible in an adversary criminal trial." (Morrissey v. Brewer, supra, 408 U.S. at p. 489.) The California Supreme Court has recognized that "parole and probation revocation hearings are equivalent in terms of the requirements of due process. " (People v. Rodriguez (1990) 51 Cal.3d 437, 441.) " 'What is needed is an informal hearing structured to assure that the finding of a . . . violation will be based on verified facts and that the exercise of discretion will be informed by accurate knowledge of the probationer's behavior.' The only rubrics prescribed for such a hearing in Morrissey were that it provide the alleged violator written notice of the claimed violations, disclosure of the evidence against him, opportunity to be heard in person and to present witnesses and documents, confrontation of adverse witnesses (unless the hearing officer specifically finds good cause for denial of confrontation), a neutral factfinder, and a written statement of the evidence relied upon and reasons for revocation. " (People v. Perez (1994) 30 Cal.App.4th 900, 904.) "Probation revocation proceedings are not 'criminal prosecutions' to which the Sixth Amendment applies. Probationers' limited right to confront witnesses at revocation hearings stems from the due process clause of the Fourteenth Amendment, not from the Sixth Amendment. " (People v. Johnson (2004) 121 Cal.App.4th 1409, 1411.) Accordingly, we apply due process standards to our analysis. Crawford v. Washington (2004) 541 U.S. 36, holding that the confrontation clause bars testimonial out-of-court statements unless the witness is unavailable and the defendant had a prior opportunity to cross-examine the witness, does not apply to probation revocation proceedings because they are not "criminal prosecutions" for purposes of the Sixth Amendment. (People v. Johnson, supra, 121 Cal.App.4th at p. 1411.) Hearsay evidence may be used at probation revocation hearings if it bears a substantial degree of trustworthiness. (Morrissey, supra, 408 U.S. at p. 489; People v. Maki (1985) 39 Cal.3d 707, 715-717.) Under this rationale, in Maki, supra, 39 Cal.3d 707, the court permitted the use of hotel and car rental receipts to establish that the defendant had left the state in violation of his parole. Maki reasoned that the evidence had sufficient indicia of reliability because the documents indisputably contained defendant's signature, dispelling the dangers of hearsay evidence. (Id. at p. 715; see also People v. O'Connell (2003) 107 Cal.App.4th 1062, 1067 documentary evidence from a court-ordered counseling service that defendant had failed to attend required sessions bore sufficient indicia of reliability because the counseling center's report had been prepared contemporaneously with and specifically for the hearing.) In Maki, our Supreme Court stated that the right of confrontation at probation revocation hearings is "not absolute and where ' "appropriate," witnesses may give evidence by document, affidavit or deposition .' " (Maki, supra, 39 Cal.3d at p. 710.) The issue in Maki was whether a defendant, whose probation had been revoked, had impermissibly left the geographical area to which he had been restricted. In addition to the probation officer's testimony that he had not given Maki permission to go to Chicago, the evidence offered by the prosecution consisted of a car rental receipt, bearing "the uncontroverted presence of defendant's signatures on the invoice," showing that he had rented a vehicle at O'Hare Field, Chicago, Illinois on January 27, 1983, and a customer receipt from the O'Hare Hyatt Regency showing that a certain sum was received from the defendant on January 28, 1983. (Id. at pp. 716-717.) There was also a factual finding that the signature on the car rental agreement was that of the defendant, who had signed two probation reports, which were admitted into evidence. (Id. at pp. 709, 716-717.) Although the Supreme Court found this case to be "a close one," the identification of defendant's signature on the printed invoice and the fact that it is "an invoice of the type relied upon by parties for billing and payment of money" was enough for the court to deem it reliable and affirm the probation revocation. (Id. at p. 717.) With respect to hearsay evidence to replace the live testimony of a witness, such evidence is inadmissible absent a showing of the witness's unavailability or other good cause. (People v. Arreola (1994) 7 Cal.4th 1144, 1159 (Arreola); People v. Winson (1981) 29 Cal.3d 711, 713-714.) In the case of live testimony, "the need for confrontation is particularly important where the evidence is testimonial, because of the opportunity for observation of the witness's demeanor." (Arreola, supra, at p. 1157.) Therefore, Arreola upheld the limitation on the use of hearsay testimony unless good cause was shown or the witness was unavailable. (Id. at p. 1159.) Arreola confirms that at a probation hearing a defendant's right to confront and cross-examine testimonial evidence "may not be dispensed with lightly" based on some amorphous conclusion that the hearsay testimony is reliable. (Arreola, supra, 7 Cal.4th at p. 1158.) Arreola set forth the requirements for a showing of good cause: the declarant is unavailable under the traditional hearsay standard of Evidence Code section 240; the declarant, although not legally unavailable, can only be brought to the hearing through great difficulty or expense, or the declarant's presence would pose a risk of harm to the declarant. (Arreola, supra, 7 Cal.4th at p. 1160.) The Arreola court noted that a finding of good cause must also be considered together with "other circumstances relevant to the issue, including the purpose for which the evidence is offered (e.g., as substantive evidence of an alleged probation violation, rather than, for example, simply a reference to the defendant's character); the significance of the particular evidence to a factual determination relevant to a finding of violation of probation; and whether other admissible evidence, including, for example, any admissions made by the probationer, corroborates the former testimony, or whether, instead, the former testimony constitutes the sole evidence establishing a violation of probation." (Arreola, supra, 7 Cal.4th at p. 1160.)