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031746P.pdf   08/25/2004  United States  v.  Miguel Carrillo
   U.S. Court of Appeals Case No:  03-1746
   Northern District of Iowa   
   Criminal Case - sentencing. Whether reviewing for clear error or plain 
   error, the district court did not err in applying a two-level increase for 
   obstruction of justice based on defendant's assault of a witness and threats 
   toward the witness's family. District court did not err in denying safety- 
   valve reduction based on the attack on the witness because it was in the 
   course of attempting to avoid detection or responsibility for his offense. 
   [PUBLISHED] [Smith, Author, with Murphy and Heaney, Circuit 
   Judges]