RICHARD S. ARNOLD, Circuit Judge.
After a jury trial, Jose Jesus Madrigal was convicted of conspiracy to possess and distribute controlled substances, in violation of 21 U.S.C. §§ 841(a)(1) and 846 (1994), promoting and facilitating an unlawful business activity involving controlled substances, in violation of 18 U.S.C. §§ 1952 and 2 (1994), and using a communication device to cause and facilitate possession with intent to distribute, in violation...
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