What constitutes "witness retaliation" in the context of Section 1513(b)?

Looking to 18 U.S.C. 1513(b)'s elements, the relevant "means" for a conviction is conduct which causes (or threatens to cause) "bodily injury" or tangible property damage. See United States v. Draper, 553 F.3d 174, 180 (2d Cir. 2009) (noting that to sustain a "witness retaliation" charge under 1513(b) the government "must establish . . . [that] the defendant engaged in conduct that caused or threatened a witness with bodily injury"). Such conduct need not be, in itself, "dishonest" in any normal sense of the word. Thus, under the definition articulated by the BIA here, it is clear that most, if not all, 1513(b) convictions are obtained without any showing of "dishonest" means. See, e.g., United States v. Yi Guo Cao, 420 F. App'x 25 (2d Cir. 2011)

Page 4