The following excerpt is from U.S. v. Armstrong, 909 F.2d 1238 (9th Cir. 1990):
United States v. Lester, 363 F.2d 68, 72 (6th Cir.1966), cert. denied, 385 U.S. 1002, 87 S.Ct. 705, 17 L.Ed.2d 542 (1967); see Gaskins, 849 F.2d at 459; United States v. Krogstad, 576 F.2d 22, 28-29 (3rd Cir.1978). Moreover, the elements necessary to convict an individual as a traditional principal also differ from the elements necessary to show the individual aided and abetted that crime, Gaskins, 849 F.2d at 459-60, but this difference does not prevent aiding and abetting from being implied in every indictment for a substantive offense. The difference between causing and aiding and abetting alone, therefore, does not prevent either or both theories from being implied in an indictment.
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