court’s evidentiary ruling: because “Congress showed ‘careful draftsmanship’ by including an intent requirement in the second paragraph, but not the first paragraph, of § 2113(a), we hold that the first paragraph of § 2113(a) des Hayes, 227 F.3d 578, 586 (6th Cir.2000); United States v. Andrews, 48 Fed.Appx. 151, 154-55 (6th Cir. 2002) (requiring the government to prove in a § 115 prosecution that “(1) the defendant conveyed a threat of physical harm to a federal official or his family; (2) the threat was intended as an act of retaliation against the federal official; and (3) this threat could reasonably be construed by the person in receipt of the threat to be actually carried out” (emphasis added)); United States v. Williams, No. 98-2010, 2000 WL 32006 at *2 (6th Cir. Jan.3, 2000) (<HOLDING>); United States v. Kamen, Nos. 98-5170/5171,
holding that the only intent necessary to convict a defendant under 18 usc  1513b for retaliating against a witness victim or informant was an intent to retaliate internal quotation marks omitted recognizing that to be in violation of 18 usc  115a1b the defendant must act with the intent to retaliate against a government employee on account of the performance of his or her official duties  holding that the official charged with responsibility to act must be an official within the doj with the authority to act in the circumstances holding that the second part of 18 usc  115a1b requires that a threat be made with the intent to retaliate against the judge after the judge has acted holding that government actor must intentionally abuse his or her power as a state official to harm state employee in order to sustain substantive due process violation