The following excerpt is from U.S. v. De Leo, 886 F.2d 1320 (9th Cir. 1989):
In this case, the trial court provided supplemental instructions in response to questions from the jury during deliberations. A supplemental charge is in addition to the original instructions and is not an independent charge. Reversible error does not occur so long as the combined instructions reviewed as a whole accurately reflect the legal issues. United States v. Nickerson, 669 F.2d 1016, 1021 (5th Cir.1982). The instructions taken as a whole correctly presented the law to the jury.
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