Sepulveda v. United States

How later courts describe this case

• vacating sentence based on unsup ported average drug quantities and number of smuggling trips
• requiring a demonstration by the defendant that the denial of a bill of particular would result in prejudice at trial, or other prejudice to a “substantial right.”
• "[T]he fact that the organization's methods and tactics evolved over time did not dictate a finding of two, three, or four separate conspiracies."
• “In reviewing for cumulative error, the court must review all errors preserved for appeal and all plain errors.”
• describing date of inception of speedy trial period