California, United States of America
The following excerpt is from People v. Yarber, G053943 (Cal. App. 2018):
the victim, and (2) the intent to avoid arrest and conviction by threatening the victim. (People v. Nichols, supra, 29 Cal.App.4th at pp. 1657-1658.) In addition, the court found the means of achieving each objective was different. The robbery was committed by placing a shotgun to the victim's head, while the second offense was committed by reading the victim's address off of his driver's license and threatening future harm. (Id. at p. 1658.)
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