25

United States v. Wells, 446 F.2d 2 (2nd Cir. 1971); Bottoson v. State, 443 So.2d 962 (Fla. 1983) (murder suspect handed written confession to two ministers intending that it be relayed to the prosecutor's office); Naum v. State, 630 P.2d 785 (Okla. App. 1981).