The following excerpt is from U.S. v. Gatzonis, 805 F.2d 72 (2nd Cir. 1986):
United States v. Viafara-Rodriguez, 729 F.2d at 913. Perhaps that opinion did not state our views on this issue strongly enough. We write now to make completely clear that district judges should not charge that "separate bits of evidence" need not be proved beyond a reasonable doubt.
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