Is a defendant required to be present at the pronouncement of a sentence?

"We review de novo the asserted discrepancy between the spoken and written terms of [a] sentence. It is a question of law whether the spoken and written terms of a defendant's sentence differ impermissibly." United States v. Washington, 904 F.3d 204, 207 (2d Cir. 2018).¹

"The Federal Rules of Criminal Procedure provide that a defendant must be present at pronouncement of sentence." Id. at 208. Therefore, after a sentence has been pronounced, the written judgment may clarify the terms of the spoken sentence, but may not add to them. See United States v. Truscello, 168 F.3d 61, 63 (2d Cir. 1999). If there is a substantive discrepancy between the spoken and written versions of a defendant's sentence, the spoken version ordinarily controls. United States v. Rosario, 386 F.3d 166, 168 (2d Cir. 2004).