The rule against hearsay generally prohibits the admission of out-of-court statements offered to prove the truth of the matter asserted. The rationale for this rule is that such statements are considered unreliable because the declarant was not under oath and is not available for cross-examination at trial. Cross-examination is seen as the 'greatest legal engine ever invented for the discovery of truth,' as it allows the opposing party to test the declarant's perception, memory, and sincerity. However, the rule against hearsay is subject to numerous exceptions for statements that are considered to have a high degree of trustworthiness despite being made out of court. For example, 'excited utterances'—statements made while under the stress of a startling event—are admitted on the theory that the stress of the moment prevents the declarant from fabricating a lie. Similarly, 'business records' are admitted because the routine and systematic nature of their creation makes them inherently reliable.