Commonwealth v. Ostrovsky, 940 N.E.2d 519, 78 Mass.App.Ct. 1122 (2011)

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  “As far as any chalk diagrams that may be used (during retrial) are concerned, the general rule is that evidence must be admitted as an exhibit in order to be considered by the jury. A judge, however, has ‘considerable, but not unrestrained, ...

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  “A thirty-four page bar chart depicting the hours the defendant billed Medicaid each day was used as a chalk at trial. "A judge . . . has `considerable, but not unrestrained, discretion as to the degree to which chalks can be used.'" Commonwealth v. ...

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