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This section contains the nature of the case and procedural background.

D was indicted in 1975. He failed to appear at a pretrial hearing and a bench warrant issued for his arrest. He was arrested in November 1979. After his arrest, a superseding indictment charged D with possession with intent to distribute heroin and bond jumping. The district court admitted a letter and two mailgrams into evidence to show that D had been sent notice of the hearing he failed to attend. D was convicted and appealed, in part, the admission of the notices.

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