The following excerpt is from United States v. Wells, 877 F.3d 1099 (9th Cir. 2017):
4. Though defense counsel did not use the terms "prejudice" or "unduly prejudicial," those concerns, at the heart of Rule 403 balancing, were clearly the basis for his statement. See United States v. Ward, , 1189 (9th Cir. 2014) ("Although defense counsel did not use the term `Fifth Amendment,' the substance of the objection was patently clear.").
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