In People v. Liggan, 62 A.D.3D 523, 878 N.Y.S.2d 735 (1" Dep't 2009), the defense became aware of the presence of news articles that he believed would prove prejudicial to his client. The defendant rejected an additional jury instruction regarding outside information. "Since counsel was aware, during the trial, of a potential danger of exposure of jurors to this information, but declined a remedy that would have obviated the need for post-verdict proceedings or a new trial, the post-verdict disclosure was not a basis for setting aside the verdict."