The following excerpt is from United States v. Morgan, 786 F.3d 227 (2nd Cir. 2015):
Evidence of threats by a defendant against a potential witness against him can ... be used to show guilty knowledge. United States v. Bein, 728 F.2d 107, 11415 (2d Cir.1984). That is certainly true when threats are inextricably intertwined with the evidence regarding the charged offense. Quinones, 511 F.3d at 309 (explaining that the record plainly demonstrates that the challenged statements constituted important proof of the charged crimes: they contained [the defendant's] admissions to the [charged] murder); cf. United States v. Tracy, 12 F.3d 1186, 1195 (2d Cir.1993) (finding no abuse of discretion when death threat evidence admitted to show defendant was a member of the conspiracy and played a role that gave him ... familiarity with [its] operation, including acting as its enforcer).
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