Frias-Cobos

MEMORANDUM ***

On appeal, Frias-Cobos claims that the trial court (1) violated his constitutional right (under the Confrontation Clause) by failing to allow him to cross-examine a cooperating co-conspirator; (2) erred by allowing the government to admit written stipulations after the government rested its case, but before closing argument or jury instruction; (3) wrongfully applied a two-level enhancement under the sentencing guidelines pursuant to its findings that one of Frias-Cobos’s co-conspirators was in possession of a firearm at the time of the crime, that the possession was in furtherance of the crime, and that the possession was reasonably foreseeable to Frias-Cobos; and (4) erred by finding Frias-Cobos ineligible for a downward adjustment pursuant to its finding that Frias-Cobos did not play a minor role in the crimes.

1. The trial court limited the scope of the defendant’s cross examination of a co-conspirator; it did not exclude an area of inquiry. “In reviewing a limitation on the scope of questioning within a given area, we recognize that ‘trial judges retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable *173 limits on such…