The following excerpt is from U.S. v. Khalaf, 976 F.2d 738 (9th Cir. 1992):
This court has held that a trial court may refuse to define reasonable doubt. United States v. Nolasco, 926 F.2d 869, 873 (9th Cir.) (en banc ), cert. denied, 112 S.Ct. 111 (1991). Nevertheless, if a trial court chooses to render a supplemental instruction, it must ensure that the instruction does not detract from the heavy burden suggested by the use of the term "reasonable doubt." Id.
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