explicitly predicated the obstruction of justice enhancement on Henry’s attempt to convince Ni-black to file a false police report. Supp. App. 339, 343. This was not error. Nonetheless, Henry argues that the District Court erred because it found that the threat against the prosecutor could support an obstruction of justice enhancement, even absent evidence that Henry intended it to be communicated to the prosecutor, thereby influencing or obstructing her prosecution of him. We have not addressed whether U.S.S.G. § 3C1.1 requires a threat to be communicated to the intended victim or the related question of what constitutes evidence of intent for the enhancement. Other circuit courts of appeals are split on the issue. See United States v. Brooks, 957 F.2d 1138, 1150-51 (4th Cir.1992) (<HOLDING>); United States v. Searcy, 316 F.3d 550, 552-53
holding that the enhancement requires that the defendant either threaten the codefendant witness or juror in his or her presence or issue the threat in circumstances in which there is some likelihood that the codefendant witness or juror will learn of the threat recognizing that informing the jury that testifying witness has agreed to cooperate with the government is a doubleedged sword as the existence of such agreement may suggest either that the witness will testify in accordance with the governments wishes regardless of the truth or that the witness will not he under threat of revocation of the agreement should the witness commit perjury holding that the state could ask leading questions of its witness a codefendant who had entered a plea after witness initially refused to answer questions in violation of her plea agreement holding that evidence of a threat to a witness by the defendant is relevant as showing an attempt to prevent a witness from testifying and avoid punishment for the crime holding that the trial courts admonition of a witness even though detailed and strongly stated did not coerce the witness because the court did not threaten or badger the witness and the court provided the witness with her own counsel to ensure that the decision was voluntary