What is the proper procedure for responding to an inquiry from the jury during the course of deliberations?

We have previously articulated a four-step "procedure that a trial judge should normally follow in responding to an inquiry from a jury during the course of jury deliberations." United States v. Ulloa, 882 F.2d 41, 42 (2d Cir. 1989). Those steps - referred to as the Ronder procedure - require that (1) the jury's questions be submitted in writing; (2) the court mark the question as a court exhibit and read it into the record; (3) the court afford counsel an opportunity to suggest appropriate responses; and (4) the question, if substantive, be read into the record in the jury's presence once the jurors are recalled. Id. at 45 (citing United States v. Ronder, 639 F.2d 931, 934 (2d Cir. 1981)).

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