What is the difference between an assault and an attempted rape?

The lack of distinct similarities between the two incidents also undercuts the notion that they show a plan. True, the earlier incident also took place on the Navajo Reservation and involved abduction and transport by car to a remote area. But, no common scheme united these two crimes nor was there evidence they were part of an ongoing conspiracy. See United States v. Powell, 587 F.2d 443, 448 (9th Cir.1978). The earlier attempted rape charge was not connected in any way with the crimes charged here and, therefore, cannot be admitted under the "plan" exception to Rule 404(b).

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