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U.S. v. Zapatka, No. 93-1805 (2nd Cir.) (44 F.3d 112) (December 29, 1994) (Judge Ellsworth A. Van Graafeiland)

This is a somewhat interesting case which deals with the interpretation of Burns v. United States, 501 U.S. 129 (1991), which held that a defendant is entitled to advance notice of a proposed departure from the applicable Guidelines sentencing range, and which some Circuits (like the 1st) have decided does …

 

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