The following excerpt is from U.S. v. Ramos-Mendez, 924 F.2d 1063 (9th Cir. 1991):
The Government bears the burden of proof when it seeks to increase a defendant's offense level. United States v. Howard, 894 F.2d 1085, 1090 (9th Cir.1990). The Government must meet the preponderance of the evidence standard. Id.
1. Pattern of Criminal Conduct
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