California, United States of America
The following excerpt is from Andrews v. County of Orange, 130 Cal.App.3d 944, 182 Cal.Rptr. 176 (Cal. App. 1982):
In civil cases a motion for new trial grounded on jury misconduct must be presented by affidavit. (Linhart v. Nelson (1976) 18 Cal.3d 641, 644-645, 134 Cal.Rptr. 813, 557 P.2d 104.)
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