United States v. McGowan, 668 F.3d 601 (9th Cir. Jan. 26, 2012) (To establish that his right to due process [at sentence] was violated, McGowan must show that the allegations were (1) false or unreliable, and (2) demonstrably made the basis for the sentence. . . . Challenged information is deemed false or unreliable if it lacks some minimal indicium of reliability beyond mere allegation.); citing United States v. Vanderwerfhorst, 576 F.3d 929, 935"36 (9th Cir.2009) (quoting United States v. Ibarra, 737 F.2d 825, 827 (9th Cir.1984); see United States v. Hanna, 49 F.3d 572, 577 (9th Cir.1995) (sentencing court violated due process by relying on allegations made under oath, but not subjected to many of the procedural mechanisms traditionally used to test witness testimony, where the jailhouse informant had everything to gain and nothing to lose by implicating the defendant, and presumably provided information to the FBI in the hope of being granted some sort of leniency, and could be expected to confirm the truth of this information when he testified at trial); cf. Gonzalez v. Wong, No. 08"99025, 2011 WL 6061514, at *33"*37 (9th Cir. Dec.7, 2011) (recounting a 1989"90 Los Angeles County Grand Jury investigation that revealed the disturbing ease and frequency with which jailhouse informants provided false testimony); United States v. Corral, 172 F.3d 714, 716 (9th Cir. 1998) (In determining whether a defendant has shown that unreliable information was demonstrably made the basis for [his] sentence, we read the record and decide whether reliance on [the] information ... probably did occur.).