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Generally, the notice requirement 'must be interpreted flexibly.' United States v. Evans, 572 F.2d 455, 489 (5th Cir.), cert. denied, 439 U.S. 870, 99 S. Ct. 200, 58 L. Ed. 2d 182 (1978) (holding that the notice requirement is satisfied so long as the opposing party has 'sufficient opportunity to determine its trustworthiness'). The Fifth Circuit has upheld the admission of evidence under the residual hearsay exception despite the impossibility of the offering party's providing the name and address of the hearsay declarant. See Universal Elec. Co. v. United States Fid. & Guar. Co., 792 F.2d 1310, 1314-15 (5th Cir.), cert. denied, 479 U.S. 987, 107 S. Ct. 578, 93 L. Ed. 2d 581 (1986) (holding that the trial court did not abuse its discretion in admitting the hearsay testimony of a deceased person under the residual hearsay exception); Dartez v. Fibreboard Corp., 765 F.2d 456, 460-63 (5th Cir. 1985) (finding that the notice requirement of the residual hearsay exception was satisfied in case involving deceased witness); see also United States v. West, 574 F.2d 1131, 1134-36 (4th Cir. 1978) (holding that the district court did not abuse its discretion where deceased witness's grand jury ...
