The following excerpt is from United States v. Pollard, 850 F.3d 1038 (9th Cir. 2017):
Pollard also challenges the legality of the forfeiture order on the grounds that the Government did not file a forfeiture allegation related to the count of conviction. Federal Rule of Criminal Procedure 32.2(a) sets forth the notice requirements for forfeiture, and "provides that a court may not enter an order of forfeiture unless the indictment or information contains notice that the government will seek forfeiture." United States v. Lo , 839 F.3d 777, 790 (9th Cir. 2016) (evaluating the adequacy of a forfeiture notice despite there being an appellate waiver). As noted above, a general appellate waiver does not prevent the court from analyzing a claim of an illegal sentence. See id. at 790 ; Bibler , 495 F.3d at 624.
[850 F.3d 1045]
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