NELSON, Circuit Judge:
Gary Halbert was convicted by a jury of twenty-one counts of mail fraud, 18 U.S.C. § 1341. On appeal, he raises four major issues. We affirm.
I
Juror Misconduct
There is an allegation that a juror improperly considered extrinsic evidence of a newspaper article about Halbert's beach house.
We independently review the allegations of juror misconduct to determine whether a new trial is justified because...
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