submit the false audit report to the SEC, thereby making him criminally liable under the federal aiding and abetting statute, 18 U.S.C. § 2(b). The government then argues that because Pan-World submitted the false audit report to the SEC within the statute of limitations period, the statute of limitations had not expired on the implicitly c st Cir.1995) (stating “an aider and abettor charge [referring to subsections 2(a) and 2(b)] is implicit in all indictments ... so it need not be specifically pleaded” (quotation omitted) (alteration in original)); United States v. Perry, 643 F.2d 38, 45 (2d Cir.1981) (stating “the provisions of 18 U.S.C. § 2 can be read into an indictment which specifically charges only a substantive offense”); United States v. Lester, 363 F.2d 68, 72 (6th Cir.1966) (<HOLDING>). Therefore, the district court erred in
holding that the fact of prior convictions under  924e need not be charged in an indictment and proven to a jury and also that the government need not charge in an indictment and prove to a jury that a defendants prior conviction constitutes a violent felony under  924e holding that trial court may charge on involuntary manslaughter only where evidence exists to support such a verdict holding an indictment need not specifically charge  causing  in order to support a jury verdict holding the failure of an indictment to expressly charge causing does not foreclose a subsequent conviction on a causation theory holding that mere speculation is insufficient to support a jury verdict