The following excerpt is from United States v. Kuzma, 967 F.3d 959 (9th Cir. 2020):
16 To the extent that we have concluded that certain potential errors were either harmless or not plain error, see supra at , we further conclude that the cumulative effect of any such potential errors is also harmless. United States v. Fernandez , 388 F.3d 1199, 125657 (9th Cir. 2004).
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