88, 92 (2d Cir.2010). Such a waiver appears to have been in Nino’s tactical interest, as a hearing might have revealed that Nino’s drug trafficking realized proceeds far in excess of $100,000. We need not here conclusively decide whether Nino’s forfeiture claim was waived or forfeited because, in any event, he fails to demonstrate error. In the agreement pursuant to which he pleaded guilty, Nino admitted that between 2000 and 2008, he had “conspired to import, distribute, or possess with intent to distribute at least 10 kilograms but less than 30 kilograms of heroin.” Government Addendum 2; see Fed.R.Crim.P. 32.2(b)(1)(B) (stating that forfeiture determination may be based “on evidence already in the record, including any written plea agreement”). The wholesale pr 29, 130 (2d Cir.1988) (<HOLDING>). Because we conclude that the evidence was
recognizing that where liability is joint and several among multiple parties complete relief may be granted with respect to any one of them holding that the surety of a joint and several bond has direct liability and may be sued individually or collectively recognizing criminal forfeiture as an aspect of punishment holding that joint and several liability for entire actual loss could have been imposed on each fraud defendant as condition of probation recognizing forfeiture liability among criminal confederates to be joint and several