In the case of United States v. Rhodes (Trial by
General Court Martial, Fort Mc. Nair, District of Columbia, 1958), Rhodes was accused as espionage. The prosecution offered into evidence microfilm obtained
from other spies that asserted that Rhodes had been recruited by the Russians
in 1952. The exhibit was offered not to prove the assertions contained
therein, but rather to show that the Russians had an inordinate interest Rhodes.
The mere presence of the Rhodes' name in the Russian files
shows something, even if the specific facts in the Russian files
aren't 100% true.
Obviously, if the jury hears this evidence it may be
misused. But jury misuse is generally not considered when determining
whether the statement is offered to prove the truth of the matter
contained in it.
What if the Russians had faked the document? Spies fake
documents all the time.
Of course, that doesn't mean that the evidence isn't
admissible, it just gives the defense an avenue to argue that the
evidence shouldn't be given much weight.