A statement made to law enforcement personnel during an investigation that focuses on the prevention of future harm rather than on gathering evidence about past facts is generally not "testimonial" and therefore is usually not subject to the constraints imposed by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution.

United States v. Goodchild, 25 F.3d 55, 61-62 (1st Cir. 1994) (upholding trial court's admission into evidence of the telephone statement memos as business records because "[the statement memos met] the strictures of the....Document must have been prepared in the normal course of business.

United States v. Gjerde, 110 F.3d 595, 603 (8th Cir. 1997) (upholding trial court's admission of the FBI agent's testimony [about Richard Field's description of Minnewaska] as a statement against interest because (1)....A statement falls within the federal hearsay exception for statements against interest only if the statement at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true.

United States v. Bruguier, 161 F.3d 1145, 1148-1150 (8th Cir. 1998) (upholding trial court's ruling which allowed the government to cross-examine the accused's opinion character evidence witnesses on their knowledge about specific incidents in order to explore the bases for holding such opinions ).When an exception to the character evidence prohibition makes evidence of a criminal defedant's character admissible, the testimony of a witness on direct examination about the defendant's character must take the form of reputation or opinion and it cannot consist of specific instances of the defendant's conduct.