WELLFORD, Senior Circuit Judge.
Defendants, Ira Silverman, Gary Catón, and Morris Woodard, have appealed from their guidelines sentences received by reason of guilty pleas to possession with intent to distribute drugs. The Chief Judge directed that their separate appeals be consolidated because he determined that “they involve similar legal questions under the Confrontation Clause.” 1 In each case, the sentencing judge increased the sentence imposed beyond that which reflected the quantity of drugs involved in the particular count or counts to which the defendant had pleaded guilty. The sentence in each case reflected other drug activity of the particular defendant based upon hearsay testimony or evidence, and this activity was found by a preponderance of the evidence by the district court to be “relevant conduct.” This relevant conduct determination was the -basis for the sentences imposed, which are the subject of these consolidated appeals. Although it is uncertain whether each of the defendants raised the confrontation issue in a timely manner, we discuss the contentions of each defendant separately and the applicable circumstances in his particular case. We AFFIRM each of the sentences.
I. IRA SILVERMAN
The saga of Silverman in the federal courts began in 1988, when he was arrested after attempting to sell cocaine to an [1504]*1504informant. The indictment charged him with intent to distribute cocaine and with a separate count of travel in interstate commerce to promote a narcotics business. Under a plea agreement, Silverman pleaded guilty only to the cocaine distribution charge. In an initial appeal, the issues were the constitutionality of the Federal Sentencing Guidelines (“guidelines”), the burden of proof on establishing guideline elements, the district court’s consideration of past activities involving drugs — found to be relevant conduct under the guidelines (§ 1B1.3) — Silverman’s role in the offense, and whether the government adhered to the plea agreement. We remanded the case (Guy, J., dissenting) to direct the district court to consider the effect of Silver-man’s plea agreement, specifically asking whether the court accepted the agreement and whether its intent had been carried out in the sentence. United States v. Silverman, 889 F.2d 1531, 1539 (6th Cir.1989). We cited, in connection with the remand, United States v. Smith, 887 F.2d 104 (6th Cir.1989), which held:
In its sentencing determination, the district court should have considered all conduct that was part of the same course of conduct or a common scheme or plan as the offense of conviction-including possession of the drugs charged in Count Two [the dismissed count].
We note that due process requires that some evidentiary basis beyond mere allegation in an indictment be presented to support consideration of such conduct as relevant to sentencing. “[A]s a matter of due process, factual matters may be considered as a basis for sentence only if they have some minimal indicium of reliability beyond mere allegation.” United States v. Baylin, 696 F.2d 1030, 1040 (3d Cir.1982); see also Williams v. Oklahoma, 358 U.S. 576, 584, 79 S.Ct. 421, 426, 3 L.Ed.2d 516 (1959). This due process limit on the evidence a sentencing court may properly consider is recognized in the commentary to § 6A1.3 of the guidelines, which provides:
In determining the relevant facts, sentencing judges are not restricted to information that would be admissible at trial. Any information may be considered, so long as it has “sufficient indicia of reliability to support its probable accuracy.” Reliable hearsay evidence maybe considered. Out-of-court declarations by an unidentified informant may be considered “where there is good cause for the nondisclosure of his identity and there is sufficient corroboration by other means.” Unreliable allegations shall not be considered.
Guidelines Manual at 6.2 (1987) (citations omitted; emphasis added).
Therefore, we reverse the district court’s sentencing of defendant and remand this case for resentencing with the instruction that all conduct that formed part of defendant’s criminal course of conduct, scheme or plan, including possession of the drug quantities charged in the dismissed count,....
Id. at 108-109 (footnote omitted). Smith reversed the district court’s failure to consider the defendant’s drug activity in the count of the indictment which was dismissed pursuant to a plea agreement.
We also directed that the district court clarify its finding on Silverman’s role in the offense, noting that the court had not indicated whether it had found five or more participants as required for a three-point enhancement. Finally, the panel directed the district court to “indicate its reasons for rejecting the motion for withdrawal of the guilty plea.” Silverman, 889 F.2d at 1540. There was no reference whatever in our previous opinion to the Confrontation Clause, nor did Silverman make any such direct contention in his brief or at argument.
In the original opinion, we noted Silver-man’s position as opposing:
consideration by the court of his past history of alleged extensive drug dealing. Defendant sought to limit consideration of evidence only to that “admissible at trial” and that proof on factors relevant to the offense level be required by “clear and convincing evidence.” He also sought to limit the sentencing hearing matters to allegations previously set forth in the presentence report (not the [1505]*1505supplemental material later presented). He sought a ruling that he could testify in response to any such evidence without waiving his fifth amendment privilege. If the ruling were adverse to defendant’s motions in this regard, Silverman sought to withdraw his guilty plea.
The district court did not specifically rule on these matters, but it did consider a later memorandum on past history of relevant conduct, dated August 19, 1988, which related to information concerning (1) investigation of Silverman by other authorities of earlier cocaine distribution, (2) a purported list of drug dealers in Silverman’s handwriting obtained in a search of the limousine, (3) Silverman’s posting while a college student of a $10,-000 cash bond in less than two hours in 1987, and (4) a November, 1987 cocaine transaction “with Silverman underlings [which] involved 93% pure cocaine.”
Silverman, 889 F.2d at 1537.
The district court reiterated its findings on Silverman’s past relevant drug conduct in the opinion on remand:
This court concluded from the evidence presented at the sentencing hearing and in the presentence investigation report that defendant was a drug dealer of significant proportion, and that his drug distribution activities spanned a period of several months prior to his arrest in February of 1988. These activities included his distribution of the kilogram of cocaine in August of 1987, as well as cocaine distribution activities as early as June of that year which were reported by the government informant. The evidence also indicated that defendant was involved in drug distribution activities at Ohio University in Athens, Ohio during or prior to this period.
Upon further consideration of the sentencing information before the court, this court reaffirms its previous factual determination that the August, 1987 sale of one kilogram of cocaine was a part of the same ongoing course of conduct or common scheme or plan as defendant’s drug activities which formed the basis for the February 15, 1988 offense of conviction. Indeed, as this court previously noted, the debt created by the August distribution of cocaine played a role in the events of February 15, 1988.
In addition, the district court concluded after further consideration on remand:
The court concludes that no promises were made to defendant that consideration of other activities as relevant conduct would be precluded, and that defendant had no basis for any expectation that the court could not consider that information.
The court concludes that there are no circumstances present in this case which would distinguish it from the result in United States v. Ykema, 887 F.2d 697 (6th Cir.1989) [, cert. denied, 493 U.S. 1062, 110 S.Ct. 878, 107 L.Ed.2d 961 (1990)].
In their appellate briefs to this court on this second appeal, the parties did not cite the Confrontation Clause or the Sixth Amendment. Silverman did object, however, to the hearsay nature of some evidence or information. Silverman’s appellate brief, moreover, acknowledged numerous cases holding that “drugs that were not part of the offense of conviction must be included in the amount used to compute the base offense score” under the guidelines. He claimed, rather than a confrontation violation, that the “record” did not support the district court’s findings.2 Regardless of whether we consider Silverman’s due process contention as a “Confrontation Clause” matter,3 we deal with the district court’s treatment of hearsay evidence.
[1506]*1506We conclude that the district court, 730 F.Supp. 1418 (1990), was not in error in its reconsideration of the issues remanded to it, including the reduction based on Silver-man’s reduced role as manager. We reiterate, without setting forth in additional detail, the findings indicated as supported by evidence in the opinion in the original appeal. We find the supplemental findings made on remand by the district court are also supported by evidence with at least “some minimum indicia of reliability.” We also conclude, for the reasons hereinafter set forth, that Silverman’s Confrontation Clause rights, as well as his due process rights, were not violated in the district court’s determination of other relevant drug conduct after consideration of the pre-sentence report, testimony by DEA agent Robins, a supplemental memorandum submitted to the district court on sentencing, the opportunity of defendant to present witnesses or to ask for a recess or continuance if surprised, and argument of counsel.
II. GARY CATON
Gary Catón was indicted by a grand jury on three counts charging him with three violations of 21 U.S.C. § 841(a) for illegal distribution, and possession with intent to distribute cocaine. The charges arose from three undercover government purchases of cocaine from Catón in 1989. Those purchases included two transactions totalling one-eighth ounce of cocaine sold to a confidential informant; the sale of one-quarter ounce from Caton’s car repair shop a few days later to the informant; and the sale of two ounces, again at the repair shop, to an undercover government agent about a month later. Catón pleaded guilty to all three charges. Probation Officer Mason prepared a presentence report following Caton’s guilty plea. After Catón made numerous objections to the report, a number of paragraphs from the presentence report were deleted.
The district court held an evidentiary hearing on the issue of whether certain alleged prior criminal activities mentioned in the presentence report were “relevant conduct” within the meaning of Guidelines § IB 1.3(a)(1). The conduct relied upon by the probation officer involved 16 to 56 kilograms of cocaine that were apparently processed through Caton’s home with Caton’s knowledge in conjunction with several drug rings including one led by Morris Woodard. The court held that “[t]he definition of relevant conduct requires a link between the past conduct and the count of conviction. In this case the other activities are too remote, in time, involvement and character, to meet this standard.” At the end of the hearing, however, the district court indicated that it was considering an upward departure.
Catón was sentenced on the basis of an offense level of fourteen and a criminal history category of six to imprisonment for forty-six months with three years’ supervised release and a $150 special assessment. The court found that an upward departure from the recommended criminal history category to the next higher level would result in too lenient a sentence. The court stated:
[T]his Court has examined the next highest criminal history category and feels that it is too lenient in this situation. The next highest criminal history category would be a two, which would call for an 18 to 24-month range. And in the opinion of this Court this is simply not enough time considering the nature and the extent of the defendant's past conduct.
So based upon the defendant's conduct as documented in the presentence report and supplemented in the evidentiary hearing, the Court will depart above the applicable guideline range.
I think departing anything lower than the category six would result in a sentence which is not serious — severe enough. I think this is a case which requires a serious sentence. And I took it a step at a time. I went from three to [1507]*1507four to five until I felt comfortable with six.
(Citing United States v. Kennedy, 893 F.2d 825 (6th Cir.1990)). The court’s determination was based on the fact that Catón was a “player” in the distribution of large amounts of cocaine.4 The court relied on information from the presentence report, the Kentucky State Police, an identified witness, a confidential informant, and Ca-tón himself. Catón objected to use of the information from the confidential informant because he felt he should have had the opportunity to learn the informant’s identity and test the reliability of the informant’s testimony by cross-examination. The discussion of the confrontation issue also relates to defendant Woodard, and we also set out the factual setting as to Woodard before beginning our analysis.
III. MORRIS WOODARD
Woodard was sentenced pursuant to the guidelines for conspiracy to possess cocaine with intent to distribute involving two kilograms in violation of 21 U.S.C. § 846. Woodard pleaded guilty to the charge in exchange for the government’s agreement not to seek enhancement above guidelines level twenty-eight. The plea agreement notified Woodard that he faced up to forty years imprisonment and that the ultimate sentence was within the district court’s discretion.
The conduct to which Woodard pleaded guilty involved the purchase from a confidential informant of one to two kilograms of cocaine. Woodard was arrested by the Kentucky State Police at his tobacco warehouse following a meeting with the confidential informant at which Woodard was prepared to purchase one or more kilograms for $22,000 per kilogram. Most of the negotiations were conducted by Woodard’s nephew, Sims, but Woodard provided the money for the cocaine.
The presentence report indicated that Woodard had been involved with two groups of cocaine dealers, one of which included defendant Catón. The report recommended a four-point enhancement based on Woodard’s role in the offense and did not recommend a two-point reduction for acceptance of responsibility. Woodard requested access to the notes and memoran-da used by the probation officer in preparing the report, but the court denied his request.
The government indicated that it would offer evidence at a hearing in support of a two (not four) level increase based on Woodard’s role and that it would oppose a two-level decrease for acceptance of responsibility. The district court twice offered Woodard the opportunity to withdraw his plea, but Woodard declined.
The district court found that Woodard was the dominant figure in the transaction, that he had used Sims as a buffer, that he made false statements about his role stating he was only a simple money lender, and that he had also falsified the facts about his intentions to sell the cocaine. On this basis the district court enhanced the base level two points to thirty and refused to reduce it for acceptance of responsibility. The court then sentenced Woodard to 121 months imprisonment.
IV.. THE CONFRONTATION ISSUE
Before entering into its analysis of the Confrontation Clause, the dissent argues that this court should not treat “the ‘relevant conduct’ provisions as sentencing ‘imperatives.’ ” We choose not to address this argument, which has never been -raised in these cases, since our recent decision in United States v. Davern, 970 F.2d 1490 (6th Cir.1992) (en banc), rejected the same contentions urged by the dissent.
Defendants argue that a criminal defendant is entitled to trial-like procedural protections at sentencing in order to challenge the accuracy of presentence reports or other information developed for the edification of the sentencing judge. This argument appears to be predicated upon a theory that all things relative to sentencing have completely changed under the [1508]*1508guideline procedures. While a number of considerations have changed, we are of the view that the permissible methods of informing the sentencing judge and the need for information in fashioning sentences in light of the constitutional rights of defendants at sentencing have not essentially changed. The standard has always been that a sentence may not properly be imposed on the basis of material misinformation, Roberts v. United States, 445 U.S. 552, 556, 100 S.Ct. 1358, 1362, 63 L.Ed.2d 622 (1980), but specific procedures, such as are required at trial, are simply not constitutionally mandated, especially when a guilty plea is entered. See, e.g., Boykin v. Alabama, 395 U.S. 238, 242, 89 S.Ct. 1709, 1711-12, 23 L.Ed.2d 274 (1969) (“A plea of guilty is more than a confession which admits that the accused did various acts; it is itself a conviction; nothing remains but to give judgment and determine punishment.”).
In Williams v. New York, 337 U.S. 241, 69 S.Ct. 1079, 93 L.Ed. 1337 (1949) the Supreme Court considered the proper application of the rules of evidence to sentencing procedures. The Court upheld New York law which allowed a judge to consider evidence obtained from outside the courtroom without confrontation or cross-examination in exercising the judge’s discretion to impose the death penalty. The Court considered the appellant’s due process claim and the effect of the policy that “no person shall be tried and convicted of an offense unless he is given reasonable notice of the charges against him and is afforded an opportunity to examine adverse witnesses.” Id. at 245, 69 S.Ct. at 1082 (footnote omitted). The court rejected the appellant’s request for trial-like procedural protections on both historical and practical grounds.
[B]oth before and since the American colonies became a nation, courts in this country and in England practiced a policy under which a sentencing judge could exercise a wide discretion in the sources and types of evidence used to assist him in determining the kind and extent of punishment to be imposed within limits fixed by law.
Id. at 246, 69 S.Ct. at 1082 (footnote omitted); see also Williams v. Oklahoma, 358 U.S. 576, 583-86, 79 S.Ct. 421, 425-27, 3 L.Ed.2d 516 (1959). The Supreme Court recognized and permitted the use of affidavits and judges’ personal knowledge in sentencing offenders, and noted as well that Rule 32 of the Federal Rules of Criminal Procédure provided that federal judges have access to reports made by probation officers. Williams v. New York, 337 U.S. at 246, 69 S.Ct. at 1082.
In Williams, the Court concluded:
[a] sentencing judge ... is not confined to the narrow issue of guilt. His task within fixed statutory or constitutional limits is to determine the type and extent of punishment after the issue of guilt has been determined. Highly relevant— if not essential — to his selection of an appropriate sentence is the possession of the fullest information possible concerning the defendant’s life and characteristics.
Id. at 247, 69 S.Ct. at 1083 (footnote omitted). The Court noted the singular value of probation presentence reports to this gathering of information process.
We must recognize that most of the information now relied upon by judges to guide them in the intelligent imposition of sentences would be unavailable if information were restricted to that given in open court by witnesses subject to cross-examination. And the modern probation report draws on information concerning every aspect of a defendant’s life. The type and extent of this information make totally impractical if not impossible open court testimony with cross-examination. Such a procedure could endlessly delay criminal administration in a retrial of collateral issues.
Id. at 250, 69 S.Ct. at 1084-85 (footnote omitted; emphasis added).
We have acknowledged the wide discretion allowed a trial judge in considering the evidence submitted at sentencing. See, e.g., United States v. Hill, 688 F.2d 18, 20 (6th Cir.) cert. denied, 459 U.S. 1074, 103 S.Ct. 498, 74 L.Ed.2d 638 (1982) (sentencing [1509]*1509court may consider presentence report information “notwithstanding the fact that [defendant] has never been prosecuted or convicted for any prior criminal activity”), Humphries v. Green, 397 F.2d 67, 70 (6th Cir.1968).
The sentencing court’s use of hearsay information has traditionally been almost unlimited. United States v. Maddalena, 893 F.2d 815, 820 (6th Cir.1989). For instance, “[sentencing courts have traditionally heard evidence and found facts without any prescribed burden of proof at all,” McMillan v. Pennsylvania, 477 U.S. 79, 91, 106 S.Ct. 2411, 2419, 91 L.Ed.2d 67 (1986) (citing Williams, 337 U.S. at 241, 69 S.Ct. at 1080), even when the presentence report was not furnished to defendants. See Fennel & Hall, Due Process at Sentencing: An Empirical and Legal Analysis of the Disclosure of Presentence Reports in Federal Courts, 93 Harv.L.Rev. 1615, 1617 (1980). One court, in reviewing the history of sentencing, has stated, “virtually no limitations were placed on what a court could consider at sentencing and it was clear that reliance on uncorroborated hearsay was permissible.” United States v. Bowman, 926 F.2d 380, 381 (4th Cir.1991) (emphasis added; footnote omitted).
Judge Breyer, a member of the Sentencing Commission, describes the result of the Sentencing Commission’s work as follows:
A sentencing guideline system must have some real elements, but not so many that it becomes unwieldy or procedurally unfair. The Commission’s system makes such a compromise. It looks to the offense charged to secure the “base offense level.” It then modifies that level in light of several “real” aggravating or mitigating factors, (listed under each separate crime), several “real” general adjustments (“role in the offense,” for example) and several “real” characteristics of the offender, related to past record.
Breyer, The Federal Sentencing Guidelines And The Key Compromises Upon Which They Rest, 17 Hofstra L.Rev. 1, 11-12 (1988) (footnotes omitted). The creation of this hybrid system was formally recognized by the Commission itself. U.S.S.G. Ch. 1, Pt. A, intro. 4(a), comment.
Relevant conduct, criminal history, and role in offense are examples of the real aspects of the sentencing guidelines. Procedural requirements for establishing the factual basis of sentencing, akin to the real offense aspects of pre-guideline sentencing, continue from former sentencing practices. See e.g., Breyer, supra at 10; LaFave & Israel, Criminal Procedure § 25.1 (Supp. 1990) (acknowledging that guidelines do not require a trial-type evidentiary hearing); Hutchison & Yellen, Federal Sentencing Law and Practice 406 (1989) (“The Federal Rules of Evidence, by their own terms, do not apply to the sentencing phase of a case. The Sentencing Reform Act did not alter that.”). According to one commentator:
The relevant-conduct principle and cross-references between guidelines often work to ensure that the offense level is based on the actual offense behavior. For offenses like drug trafficking, theft, fraud, or tax evasion, conduct from uncharged or dismissed counts is often aggregated through application of the relevant conduct guideline section, lB1.3(a)(2)....
Amendments promulgated since the original guidelines, and new proposals being considered in 1992, move the guidelines further toward a real-offense system.
Paul J. Hofer, Plea Agreements, Judicial Discretion, And Sentencing Goals, FJC DIRECTIONS, No. 3, May 1992, at 3.
Amended Fed.R.Crim.P. 32 deals with “sentence and judgment:”
Sentence and Judgment
(a) Sentence.
(1) Imposition of sentence. ... At the sentencing hearing, the court shall afford the counsel for the defendant and the attorney for the Government an opportunity to comment upon the probation officer’s determination and on other matters relating to the appropriate sentence. Before imposing sentence, the court shall also—
[1510]*1510(A) determine that the defendant and defendant’s counsel have had the opportunity to read and discuss the presen-tence investigation report....
(B) afford counsel for the defendant an opportunity to speak on behalf of the defendant; and
(C) address the defendant personally and determine if the defendant wishes to make a statement and to present any information in mitigation of the sentence. The attorney for the Government shall have an equivalent opportunity to speak to the court.
(c) Presentence Investigation.
(1) When Made. A probation officer shall make a presentence investigation and report to the court before the imposition of sentence....
(2) Report. The report of the presen-tence investigation shall contain—
(A) information about the history and characteristics of the defendant, including prior criminal record, if any, financial condition, and any circumstances affecting the defendant’s behavior that may be helpful in imposing sentence or in the correctional treatment of the defendant.
(B) the classification of the offense and of the defendant under the categories established by the Sentencing Commission pursuant to section 994(a) of title 28, that the probation officer believes to be applicable to the defendant’s case; the kinds of sentence and the sentencing range suggested for such a category of offense committed by such a category of defendant as set forth in the guidelines issued by the Sentencing Commission pursuant to 28 U.S.C. 994(a)(1); and an explanation by the probation officer of any factors that may indicate that a sentence of a different kind or of a different length from one within the applicable guideline would be more appropriate under all the circumstances.
(3) Disclosure.
(A) At least 10 days before imposing sentence, unless this minimum period is waived by the defendant, the court shall provide the defendant and the defendant’s counsel with a copy of the report of the presentence investigation,.... The court shall afford the defendant and the defendant’s counsel an opportunity to comment on the report and, in the discretion of the court, to introduce testimony or other information relating to any alleged factual inaccuracy contained in it.
(D)If the comments of the defendant and the defendant’s counsel or testimony or other information introduced by them allege any factual inaccuracy in the pre-sentence investigation report or the summary of the report or part thereof, the court shall, as to each matter controverted, make (i) a finding as to the allegation, or (ii) a determination that no such finding is necessary because the matter controverted will not be taken into account in sentencing.
(Emphasis added).
This amended rule allows a greater disclosure of presentence reports to the defendant, but reliance upon these reports is still contemplated without the full panoply of trial procedures available to a defendant at trial. In short, confrontation rights do not apply in sentencing hearings as at a trial on the question of guilt or innocence. When defendants have pleaded guilty, as in this case, sentencing does not mandate confrontation and cross-examination on information submitted to the court through the presentence reports and law enforcement sources. Following the mandates of Fed. R.Crim.P. 32 is constitutionally sufficient because they are fundamentally fair and afford the defendant adequate due process protections.
Rule 32(c)(3)(A) affords defendants the opportunity “to introduce testimony or other information” at the sentencing hearing. Presentence reports frequently contain hearsay information from confidential and unidentified sources. In the event of controversy concerning the accuracy of the presentence report, Rule 32(c)(3)(D) mandates that the sentencing judge either make a finding or disregard the contested [1511]*1511matter in arriving at a sentence. Rule 32, as amended, clearly applies to required procedures under the sentencing guidelines. See United States v. Blanco, 888 F.2d 907 (1st Cir.1989). The rule is silent as to the application of the Confrontation Clause. Hearsay information submitted through law enforcement sources, or otherwise, and incorporated into a presentence report may be attacked or impeached by the defendant in a number of ways without requiring confrontation of underlying sources, which may involve confidentiality, security and personal safety.
Since the adoption of the sentencing guidelines, there has been no change in this basic statutory guide to sentencing:
Use of information for sentencing
No limitation shall be placed on the information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence.
18 U.S.C. § 3577. Under that section and based on principles discussed, the law has long been established that various types of hearsay information may be considered by the sentencing judge. See United States v. Garcia, 725 F.2d 52 (6th Cir.1984); United States v. Burton, 631 F.2d 280 (4th Cir.1980); United States v. Marshall, 519 F.Supp. 751 (E.D.Wis.1981), aff'd, 719 F.2d 887 (7th Cir.1982). It is the law that even illegally obtained or other inadmissible evidence may be considered by the sentencing judge unlike at a trial involving guilt or innocence. See United States v. Baylin, 696 F.2d 1030 (3d Cir.1982); Hill, 688 F.2d at 20; Smith v. United States, 551 F.2d 1193 (10th Cir.), cert. denied, 434 U.S. 830, 98 S.Ct. 113, 54 L.Ed.2d 90 (1977); United States v. Williamson, 567 F.2d 610 (4th Cir.1977); United States v. Lee, 540 F.2d 1205 (4th Cir.), cert. denied, 429 U.S. 894, 97 S.Ct. 255, 50 L.Ed.2d 177 (1976). Such information, on the other hand, may not be admitted at trial concerning guilt or innocence because of Fifth and Sixth Amendment concerns. The long-established principle in all of these cases, both before and after adoption of the Guidelines, is that the constitutional protections afforded defendants at a criminal trial, including confrontation rights, are not available at sentencing proceedings to limit the court’s, consideration of the background, character and conduct of the defendant.
So long as the evidence in the presen-tence report bears “some minimal indicia of reliability in respect of defendant’s right to due process,” the district court, after adoption of the guidelines, may still continue to consider and rely on hearsay evidence without any confrontation requirement. United States v. Herrera, 928 F.2d 769 (6th Cir.1991); United States v. Robinson, 898 F.2d 1111, 1115 (6th Cir.1990); United States v. Giltner, 889 F.2d 1004, 1007 (11th Cir.1989); United States v. Smith, 887 F.2d 104 (6th Cir.1989).
In Robinson, we relied upon Williams v. New York, 337 U.S. 241, 69 S.Ct. 1079, and United States v. Tucker, 404 U.S. 443, 92 S.Ct. 589, 30 L.Ed.2d 592 (1972). In reaching its decision, the Robinson court quoted the Tucker language: “a judge may appropriately conduct an inquiry broad in scope, largely unlimited either as to the kind of information he may consider, or the source from which it may come.” Tucker, 404 U.S. at 446, 92 S.Ct. at 591. See also 18 U.S.C. § 3577; United States v. Castellanos, 904 F.2d 1490 (11th Cir.1990); Blanco, 888 F.2d at 907.
Under the Sixth Amendment a defendant has the right: (1) “to a speedy and public trial”; (2) to trial “by an impartial jury”; (3) “to be informed of the nature and cause of the accusation”; (4) to “compulsory process for obtaining witnesses in his favor,” as well as confrontation of witnesses; and (5) to “assistance of counsel.” Many of these rights, applicable at trial, are not applicable to the sentencing process. (Speedy trial, jury trial, and confrontation rights are among those in the latter category).
In addition, United States v. Bronaugh, 895 F.2d 247 (6th Cir.1990), and United States v. Miller, 910 F.2d 1321 (6th Cir.1990), cert. denied, — U.S. -, 111 S.Ct. 980, 112 L.Ed.2d 1065 (1991), upheld a sen[1512]*1512tencing court’s factual finding and sentence based largely on uncharged drug conduct. (Chief Judge Merritt,- dissenting in Miller, unsuccessfully asserted Sixth Amendment limitations). See also United States v. Mocciola,. 891 F.2d 13, 16 (1st Cir.1989).
The right to be informed of the nature and the full extent and implications of criminal. charges is deemed essential for the trial process, but applies in sentencing only if an entirely new and more serious charge is added at sentencing without notice or “any ‘hearing in the normal sense.’ ” See Specht v. Patterson, 386 U.S. 605, 608, 87 S.Ct. 1209, 1211, 18 L.Ed.2d 326 (1967), as described in McMillan, 477 U.S. at 88-89, 106 S.Ct. at 2417.
In Robinson, we discussed the type of evidence made available and relied upon customarily in posi-guidelines - sentencing hearings, the very type of evidence considered by the trial judge in each of the cases now under consideration in this appeal.
Title 18, U.S.C. § 3577, states that “[n]o limitations shall be placed on the information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence.” Courts have noted that “this statute was enacted in order to clearly authorize the trial judge to rely upon information of alleged criminal activity for which the defendant had not been prosecuted....” Smith v. United States, 551 F.2d 1193, 1196 (10th Cir.), cert. denied, 434 U.S. 830, 98 S.Ct. 113, 54 L.Ed.2d 90 (1977) (citing United States v. Tucker, 404 U.S. 443, 92 S.Ct. 589, 30 L.Ed.2d 592 (1972); Williams v. People of the State of New York, 337 U.S. 241, 69 S.Ct. 1079, 93 L.Ed. 1337 (1949)). “[A] judge may appropriately conduct an inquiry broad in scope, largely unlimited either as to the kind of information he may consider, or the source from which it may come.” United States v. Tucker, 404 U.S. at 446, 92 S.Ct. at 591, quoted in Roberts v. United States, 445 U.S. 552, 556, 100 S.Ct. 1358, 1362, 63 L.Ed.2d 622 (1980). See also Alabama v. Smith, [490 U.S. 794], 109 S.Ct. 2201, 104 L.Ed.2d 865 (1989). Sentences imposed on the basis of material misinformation under some circumstances, however, may violate due process. Roberts, 445 U.S. at 556, 100 S.Ct. at 1362.
The district court may consider hearsay evidence in determining sentence, but the accused must be given an opportunity to refute it, and the evidence must bear some minimal indicia of reliability in respect of defendant’s right to due process. United States v. Rodriguez, 765 F.2d 1546, 1555 (11th Cir.1985); United States v. Otero, 868 F.2d 1412 (5th Cir.1989). In challenges to the evidence considered by the sentencing judge, the defendant must establish that the challenged evidence is materially false or unreliable, and that such false or unreliable information actually served as the basis for the sentence. Rodriguez, supra.
Robinson, 898 F.2d at 1115-16 (emphasis added).
The guidelines themselves provide that “the [sentencing] court may consider relevant information without regard to its admissibility under the rules of evidence applicable at trial, provided that the information has sufficient indicia of reliability to support its probable accuracy.” U.S.S.G. § 6A1.3 (emphasis added). The defendant in each of these cases on appeal was given “an opportunity to refute” information in the presentence report or from law enforcement sources. In each instance, the sentencing judge found the evidence sufficiently reliable to support a proper preponderance of evidence finding.
In Herrera, the defendant made the same-type of objection made by Silverman, Catón, and Woodard about unreliability of the presentence report. This court overruled Herrera’s argument:
We note that due process requires that some evidentiary basis beyond mere allegation in an indictment be presented to support consideration of such conduct as relevant to sentencing. “[A]s a matter [1513]*1513of due process, factual matters may be considered as a basis for sentence only if they have some minimal indicium of reliability beyond mere allegation.” United States v. Baylin, 696 F.2d 1030, 1040 (3d Cir.1982); see also Williams v. Oklahoma, 358 U.S. 576, 584, 79 S.Ct. 421, 426, 3 L.Ed.2d 516 (1959). This due process limit on the evidence a sentencing court may properly consider is recognized in the commentary to § 6A1.2 of the guidelines, which provides:
“In determining the relevant facts, sentencing judges are not restricted to information that would be admissible at trial. Any information may be considered, so long as it has ‘sufficient indicia of reliability to support its probable accuracy.’ Reliable hearsay evidence may be considered. Out-of-court declarations by an unidentified informant may be considered ‘where there is good cause for the nondisclosure of his identity and there is sufficient corroboration by other means.’ Unreliable allegations shall not be considered.”
Guidelines Manual at 62. (1987) (citations omitted; emphasis added).
Herrera, 928 F.2d at 773 (citing language from United States v. Smith, 887 F.2d at 108).
Thus, this court, in the recent past, in Smith, Robinson, and Herrera, has upheld the procedures at sentencing utilized by the district courts in these consolidated appeals. In each case, the guidelines procedure, as well as the traditional procedure in sentencing matters, permits hearsay, even “second hand” hearsay, from informants and unidentified sources in presentence reports, without confrontation, if the district court finds it to have “sufficient or minimally adequate” indicia of reliability. Judge Martin stated specifically:
This issue has already been resolved against Herrera by this circuit in United States v. Smith, 887 F.2d 104 (6th Cir.1989), where we held that conduct beyond that alleged in the indictment may be considered as long as there is a minimum indication of its reliability: “[a]ny information may be considered, so long as it has ‘sufficient indicia of reliability to support its probable accuracy. ’ ” Id. at 108 (citation omitted).
Herrera, 928 F.2d at 774 (emphasis in original).
Our decision reiterates what this court has consistently held — that relevant conduct proof must be found to have “sufficient indicia of reliability to support its probable accuracy” as a matter of due process protection. Smith, 887 F.2d at 108. See also, in particular, Herrera, 928 F.2d at 773, and Robinson, 898 F.2d at 1115. The Supreme Court has emphasized the breadth of information available to the district court at sentencing. It is simply incorrect, therefore, to state, as does Chief Judge Merritt in his dissent, that we hold that “constitutionally reliable evidence of the unconvicted crime is unnecessary.” We have applied the preponderance of the evidence standard long adopted by this court and supported by virtually unanimous authority.
The dissenters conclude that the sentencing judge in the Silverman case committed clear error, based on “triple hearsay,” in finding the relevant conduct evidence sufficiently reliable to add drug quantities to the amount involved in the offense to which he pleaded guilty for sentencing purposes. The district court found substantially as indicated in Silverman’s presen-tence report:
In October of 1987, he learned from a confidential informant that the informant had been obtaining cocaine from defendant during the summer of 1987 for the purpose of selling it. The informant reported that in July and August of 1987, defendant gave a kilogram of cocaine to the informant and a co-conspirator, identified as James Michael Mourning, for the purpose of selling it. They had a hard time selling that quantity of cocaine and collecting from their distributors, and ended up owing money to defendant. The informant’s information was corroborated by Mike Mourning upon his arrest on February 15, 1988. Mike Mourning told Agent Robins that he had been selling cocaine for defendant for two to [1514]*1514three years and that he had been involved in the distribution of the kilogram of cocaine. Mike Mourning also stated that he had gone to New York on two occasions and obtained a half pound of cocaine from defendant each time. He stated that defendant owned the safe which was kept at the Mourning address.
Silverman, 889 F.2d at 1533, 1534. In addition, the district court found, based on what he also deemed to be established by sufficient indicia of reliability:
Defendant admitted to the probation officer that he was going to Athens, Ohio that day to attempt to sell the cocaine, and that he had been involved previously in drug related activities in Athens and Meigs Counties.
Id. at 1533.
This evidence of admissions, statements of co-conspirators (against their interest), and police investigation does not constitute “triple hearsay,” nor does it constitute “hearsay three and four levels deep” in any of these cases as mistakenly characterized by the dissenters.
We expressly reject the sole authority to the contrary, United States v. Fortier, 911 F.2d 100 (8th Cir.1990). Fortier held that in order to require that “the government make its proof in a reliable fashion” at sentencing, it would impose a confrontation requirement based on the unusual factual situation involved.5 In that case, however, the appellate court found that the district court made, or could make, “[n]o finding of reliability.” Id. at 103.6
We cite with approval from among a plethora of cases from other circuits that conform to our conclusion on the inapplicability of the Confrontation Clause to the sentencing procedure. See, e.g., United States v. Lopez, 898 F.2d 1505, 1512 (11th Cir.1990); United States v. Beaulieu, 893 F.2d 1177, 1180 (10th Cir.1990); Giltner, 889 F.2d at 1007; United States v. Agyemang, 876 F.2d 1264, 1271 (7th Cir.1989); United States v. Carmona, 873 F.2d 569, 574 (2d Cir.1989).
Caton’s specific Confrontation issue was that the government attorney ex parte referred to hearsay information from a “confidential informant” source, and a principal government witness at the sentencing hearing gave testimony about “alleged reliability” of the informant.
The district court considered a full pre-sentence report, a 12-page presentencing [1515]*1515brief for Catón,7 granted defendant a continuance before the sentencing hearing, considered a supplemental presentence brief by Catón, and the testimony of Probation Officer Mason and Detective Ray of the Kentucky State Police at the hearing, which testimony it specifically determined to be “reliable,” before passing sentence upon Catón. Besides the confidential informant, another defendant, Phillips, also involved in drug dealing, provided the probation officer with information about Catón. The district court determined some drug conduct not to be “relevant conduct” because there was “not a sufficient nexus.” The court also considered Caton’s lawyer’s specific objections to the presentence report at the sentencing hearing. Catón admitted allowing Phillips to use his home “for a three to four month period” for drug dealing and that “four to five kilograms came through the premises during that period of time.” Caton’s lawyer stated they knew the person who they “believe might have been the confidential informant.”8 Catón admitted consuming cocaine infrequently and that his live-in companion was “consuming a good deal of cocaine.” There was no basis established by Catón that would mandate the revelation of the informant’s identity.
Catón objected that he was not a major player in cocaine dealing but admitted, through his lawyer: “[TJrue he was a player ... and he doesn’t deny that.” We find no error in the district court’s handling of the voluminous sentencing information submitted to him, and accordingly affirm the district court’s sentence of defendant Ca-tón.
What has already been said establishes that Woodard also has no legitimate constitutional claim. Woodard takes issue first with the refusal of the district court to award him a two-point reduction in his offense level for acceptance of responsibility based essentially upon his plea of guilty. He acknowledged in his brief, however, that his plea alone is not sufficient under United States v. Guarin, 898 F.2d 1120 (6th Cir.1990), and that the burden is upon him to prove facts to support a reduction. See United States v. Rodriguez, 896 F.2d 1031 (6th Cir.1990). The district court’s decision on this issue is not clearly erroneous because Woodard did not satisfy acceptance of responsibility standards. See United States v. Christoph, 904 F.2d 1036 (6th Cir.1990), cert. denied, — U.S. -, 111 S.Ct. 713, 112 L.Ed.2d 702 (1991).
Next, Woodard challenged the addition of two points based on the district court's finding that he had an aggravating role under U.S.S.G. § 3B1.1. He acknowledges that his co-defendant and relative, Sims, implicated him as a participant in the drug offenses. Woodard also admitted that he was “the source of the money for the purchase of cocaine,” and Sims’ “partner.” The problem in this regard was whether the prosecution failed to adhere to the plea agreement in which it agreed not to take a position on this issue. While we are persuaded that the court had evidence to support the two-point addition to the base offense level, we will remand for consideration by -the court as to whether the government took a position at sentencing contrary to the plea agreement. See United States v. Nelson, 837 F.2d 1519 (11th Cir.), cert. denied sub nom. Waldhart v. United States, 488 U.S. 829, 109 S.Ct. 82, 102 L.Ed.2d 58 (1988).
Woodard takes only two pages in his brief to argue the issue that it was error to deny him “the opportunity to inspect the probation officer’s notes of interviews from which he gave hearsay testimony against appellant.” In support of his argument, he cites Giltner. That case, however, as previously pointed out, supports the government’s position. Woodard concedes that Giltner specifically permits consideration of hearsay information at sentencing. [1516]*1516Giltner, 889 F.2d at 1007. He is correct in his argument that United States v. Barrett, 890 F.2d 855 (6th Cir.1989)9 (the only other case he cites), holds that “[t]he extent of a defendant’s constitutional right is ‘not to be sentenced on the basis of invalid information,’ ” and that a defendant “must be given an opportunity to rebut any challenged information.” Id. at 865 (emphasis added); see also United States v. Stevens, 851 F.2d 140, 143 (6th Cir.1988). Since Woodard was given an opportunity to explain or rebut any challenged information, he must fail in his contention that he be ordered access to the probation officer’s notes of interviews with other participants and sources of information on Woodard’s role in the offense. Woodard cites no authority that gives him the right he sought in his brief to obtain these interview notes, if they exist.
The district judge considered testimony from Woodard’s nephew, among others, that Woodard used “people as a buffer; it was Woodard’s money; it was Woodard’s deal.” Having heard Woodard’s testimony about a major transaction for a kilo of cocaine, the district court found that he “willfully lied to the court,” and that “he lied to the probation officer.” Before passing sentence, the experienced district judge had before him a lengthy presentence report, a detailed response, and objections to that report, notice by the government that it would seek an increase in offense level, defendant’s 14-page sentencing memorandum, testimony of the probation officer subject to cross-examination, and testimony of the defendant. The probation officer testified that Sims, Gary Catón,10 and Ronnie Simpson (defendant in another related drug offense), among others, were sources of information on Woodard’s role for the presentence report as well as Kentucky State Police records.
Woodard conceded that he was involved as a “middleman for tobacco people” in a number of cocaine transactions, but he claimed that they were “non-profit” arrangements. He persuaded Sims to surrender on the drug charges, and told him “its as much my fault as it is yours.”
We find no error in the sentencing procedure as to defendant Woodard, except we remand with regard to whether the government reneged on its plea agreement, and if so, what effect this may have had on the ultimate sentence.
For the reasons stated, we AFFIRM the sentences as to defendants Silverman and Catón. We also AFFIRM in most regards as to defendant Woodard, but REMAND on the limited question of the government’s alleged violation of the plea agreement.