Whether the government breaches a plea agreement and violates due process when it endorses additional Guidelines enhancements not listed in sentencing stipulations based on generalized disclaimer language

1. Whether the government breaches a plea agreement, and violates due process under Santobello v. New York , 404 U.S. 257 (1971), when it enters into an agreement containing a section labeled “Sentencing Stipulations” specifying certain Sentencing Guidelines adjustments, but later endorses additional Guidelines enhancements not listed in those stipulations at sentencing based on generalized disclaimer language elsewhere in the agreement—thereby substantially increasing the defendant’s sentencing exposure beyond what the plea reasonably conveyed and the defendant reasonably understood