2. Identify the specific hearsay dangers raised by those aspects of the
statement in the particular circumstances of the case;
3. Based on the circumstances and these dangers, consider alternative, even speculative, explanations for the statement; and
4. Determine whether, given the circumstances of the case, the corroborative evidence led at the voir dire rules out these alternative
explanations such that the only remaining likely explanation for
the statement is the declarant’s truthfulness about, or the accuracy
of, the material aspects of the statement.
 It is important to recognize that the Supreme Court’s ruling
in Bradshaw created a much more onerous test for the admission
of a hearsay statement than existed at the time of the appellant’s
trial. As Chris D.L. Hunt and Micah B. Rankin described in their
article, “R. v. Bradshaw: The principled approach to hearsay revis-
ited” (2018), 22:1 Intl. J. Evidence & Proof 68, at p. 74:
. . . the majority’s framework creates a far more restrictive standard for the
admissibility of corroborative evidence. This is reflected in the second and
third steps of the new framework; namely, the requirement that trial judges
identify alternative (and even speculative) explanations for the hearsay
statement and the requirement that the corroborative evidence must show
the truthfulness of the statement to be the only likely explanation. As Justice
Moldaver observed in dissent, this approach appears to mean that “for a piece
of corroborative evidence to make its way onto the evidentiary scale for
threshold reliability purposes, it must effectively be independently capable of
tipping the scale”.
(Emphasis in original)
 In the next section of my reasons, I consider how that
more restrictive standard applies to the impugned statements in
the case at bar. I note that because the trial judge did not have
the benefit of the Supreme Court’s decision in Bradshaw, she did
not apply this test in her ruling on the admissibility of the hearsay statements.
(c) Application of Bradshaw
 The application of the four-step framework provided by
the Supreme Court in Bradshaw to the statements of Messrs.
McLellan and Mullen makes clear that they should not have been
admitted for the truth of their contents.
 Turning to the first part of the analysis, the material parts
of the statements being tendered for their truth were ( i) that the
appellant had given the Toronto Three clothing to wear during
the robbery, and ( ii) that the appellant had driven out with the
Toronto Three to Mr. Swan’s house to point out the location
of the residence. In addition, in Mr. McLellan’s statement he told
the police that the appellant had first proposed the idea of