3.9(e) DEFENDANTS STATEMENTS A statement claimed to have been made by [name of defendant] outside of court has been placed before you. Such a statemt should always be considered with caution enand be weighed with great care to macertain it was freely ke and voluntarily made. Therefore, you must determine from the evidence that [name of defendant]s alleged statement was knowingly, voluntarily and freely made. In making this determination, you should consider the total circumstances, including but not limited to: 1. Whether, when [name of defendant] made the statement, me of defendant] had been threatened in order to get [name of defendant] to make the statement, and 2. Whether anyone had promised [name of defendant] anything in order to get [name of defendant] to make the statement. If you conclude [name of defendant]s out of court statement was not freely and voluntarily made, you should disregard it.