California, United States of America
The following excerpt is from The People v. Bryant, B219277, No. BA346025 (Cal. App. 2011):
and this court's decision in People v. Hedgecock (1990) 51 Cal.3d 395 is not to the contrary]; People v. Williams (1988) 45 Cal.3d 1268, 1318[-1319] ['The sole evidence of the alleged misconduct was the declaration of a defense investigator that purports to relate a conversation with [a] juror. It is settled, however, that "a jury verdict may not be impeached by hearsay affidavits."'].)"
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