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State v. Henderson and the New Model Jury Charges - New Jersey ...

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Private Actors.<br />

•Private Actors = Can equal <strong>State</strong> action<br />

– <strong>State</strong> v. Chen, 208 N.J. 307 (2011)<br />

•Did law enforcement elicit from <strong>the</strong><br />

eyewitness whe<strong>the</strong>r he or she had spoken<br />

with anyone about <strong>the</strong> identification <strong>and</strong>, if<br />

so, what was discussed?

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