The following excerpt is from U.S. v. Ford, 977 F.2d 592 (9th Cir. 1992):
Similarly, the record contains no information on the similarity of the offenses. Both crimes were armed robberies, but the particular circumstances of the robberies were not discussed. Even if the circumstances were known, United States v. Davis, 922 F.2d 1385, 1391 (9th Cir.1991), held that a common modus operandi alone is not enough to establish that the cases are related.
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