The following excerpt is from U.S. v. Keegan, 61 F.3d 913 (9th Cir. 1994):
This court recently considered an issue nearly identical to the one at bar in United States v. France, No. 94-50245, 1995 WL 358563 (9th Cir. June 16, 1995). In that case, the defendant handed a bank teller a note demanding, "Give me all the 100s and 50s in your drawer. I have dynamite." Id. at * 1. Affirming a two-level enhancement of the defendant's sentence, this court held:
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