zi, supra note 44, ECF No. 309; see also Order, United States v. O'Shea, No. 09-cr-629 (S.D. Tex. Jan. 3, 2012), ECF No. 142; Order, United States y. Nguyen, No. 08-cr-522 (E.D. Pa. Dec. 30, 2009), ECE No. 144. These district court decisions are consistent with the acceptance by district courts around the