at 1256 - (citing United States v. Jeffries, 587 F.3d 690, 691-695 (5th Cir.2009) (rejecting the emboldenment theory when the defendant took a gun from another man after a violent altercatioh, got into his car, and picked up his girlfriend;- the police stopped the defendant ‘almost immediately thereafter, and found the gun on the driver’s seat and a rock of cocaine on the floor behind the seat, because, even if the cocaine belonged to the defendant, thé évi-dence was insufficient to establish that the gun emboldened him); United States v. West, 643 F.3d 102, 115-16 (3d Cir.2011). (rejecting application of emboldenment theory when marijuana found in glove compartment and revolver found in backpack in trunk of defendant’s car); United States v. Smith, 535 F.3d 883, 886 (8th Cir.2008) (<HOLDING>)). The Tenth Circuit emphasized that the
holding that the presence of firearms may go toward proving that a defendant possessed drugs with the intent to distribute holding that the pretrial order did not adequately disclose a theory because it did not give notice of that theory holding that the fortress theory was applicable where it reasonably appeared that the gun was used to protect the drugs given that the drugs and firearm were found in the same location holding that emboldenment theory not applicable because defendant did not venture from home into public with the drugs or firearms holding that public meeting did not satisfy public participation requirement because public did not receive adequate notice