F.3d 832, 834 (6th Cir.2013) (considering the district court’s written opinion memorializing a prior oral ruling, even though opinion was written after notice of appeal); In re Grand Jury Proceedings Under Seal, 947 F.2d 1188, 1190 (4th Cir.1991) (same); Blaine v. Whirlpool Corp., 891 F.2d 203, 204 (8th Cir.1989) (same). In fact, the Court of Appeals for the Eleventh Circuit has specifically held that a sentencing court has jurisdiction to issue a post-judgment, post-appeal supplemental order detailing its rationale for a sentencing departure because such an order facilitates, rather than interferes with, the review of the appeal. See United States v. Vernier, 152 Fed.Appx. 827, 835-836 (11th Cir.2005). 2 . Skilling v. United States, 561 U.S. 358, 130 S.Ct. 2896, 177 L.Ed.2d 619 (2010) (<HOLDING>); United States v. Skilling, No. 4:04-CR-25-2
holding honest services statute covers only bribery and kickback schemes holding that an attorneys services were personal services rendered or labor done under the predecessor statute to section 38001 holding that  2000e16 covers only those individuals in a direct employment relationship with a government employer recognizing that generally services that benefit debtor are services that facilitate completion of a case holding good faith and honest error in judgment instructions erroneously imply only badfaith and dishonest deviations actionable