Burns

—Appellant was convicted, following a jury trial, of four counts of first degree murder (Pen. Code, § 187) with a finding of a multiple-murder special circumstance based on the foregoing convictions (Pen. Code, § 190.2, subd. (a)(3)). In accordance with the jury’s determination at the penalty phase of the trial, the court, after , denying appellant’s motion for new trial, sentenced appellant to life imprisonment without possibility of parole. Appellant challenges his conviction on the following grounds: (1) the trial court erred in instructing the jury that an accomplice must be shown to have shared the intent of the perpetrator of the offense; (2) his Fourth Amendment rights were violated by the admission in evidence of a letter seized by a deputy sheriff who observed appellant passing it to his confederate Tiequon Cox while both were inmates in the county jail, and additionally the trial court erred in not excluding the letter as unduly prejudicial under Evidence Code section 352; (3) his right to counsel was violated by the admission in evidence of testimony of another inmate relating statements made by appellant at the jail, and additionally the trial court erred in…