THE THREE MODES OF LITIGATING THE ADMISSIBILITY OF STATEMENTS IN CALIFORNIA ARE DISCUSSED. THEY INCLUDE COMMON LAW MOTIONS, STATUTORY VOLUNTARINESS MOTIONS, AND DIRECT AND INDIRECT STATUTORY MOTIONS ATTACKING STATEMENTS. SUBSTANTIVE CONSIDERATIONS TAKEN INTO ACCOUNT INCLUDE CUSTODY, LAWFUL CUSTODY, ADMONITIONS FROM THE PROSECUTOR TO THE ACCUSED REMINDING THE ACCUSED THAT FURTHER STATEMENTS MUST FOLLOW FROM HIS INITIATIVE, VOLUNTARINESS, AND THE METHODS USED IN DOCUMENTING THE STATEMENT OR CONFESSION. VIDEOTAPING OR FILMING THE CONFESSION IS THE MOST CREDIBLE METHOD.