Evidence of bias remains an exception to both the hearsay rule and the finality rule for collateral questions, but the fresh evidence must actually support the inference of fabrication when tested by oral examination. The quashing of convictions for a separate incident does not automatically cast doubt on a conviction arising from a different incident supported by independent evidence. For sentencing on breaches of violence restraining orders, the need for general and individual deterrence will ordinarily outweigh subjective or mitigatory considerations.
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