“guilty of the aggravat (2nd Cir.1995) (“An oral grant of a motion for acquittal is no more than an interlocutory order, which the court has inherent power to reconsider and modify ... prior to the entry of judgment.”) (internal quotation marks omitted) (quoting United States v. LoRusso, 695 F.2d 45, 52-53 (2nd Cir.1982)). We are not persuaded and decline the invitation to import such a rule into New Mexico for three reasons. {24} First, Defendant has not meaningfully distinguished this case from the general rule in New Mexico that oral rulings are ineffective and are not final judgments. Smith, 101 N.M. at 356, 683 P.2d at 38 (stating that a written order that is never filed is equivalent to an oral ruling and therefore is not a final judgment); Diaz, 100 N.M. at 525, 673 P.2d at 502 (<HOLDING>). The two current exceptions to this rule are
holding that if the record does not reflect that the sentence was pronounced in the defendants presence there is no sentence and the court is without jurisdiction to entertain an appeal holding that a court is free to change an orally pronounced sentence until a written judgment is filed holding that once a sentence is imposed it is a valid final judgment until it is reversed or vacated holding that modification of judgment and sentence to reflect an hfo designation that was not orally pronounced at sentencing violated double jeopardy and constituted an illegal sentence holding that sentence is imposed when the district court orally pronounces it