The following excerpt is from Henderson v. State of Wash., 959 F.2d 240 (9th Cir. 1992):
A defendant is entitled to a new trial when the jury obtains or uses extrinsic evidence only if there is a reasonable possibility that the material could have affected the verdict. Dickson v. Sullivan, 849 F.2d 403 (9th Cir.1988).
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