Appealing the judgment in a criminal case, Eduardo Armendaris-Ramos raises an argument that he concedes is foreclosed by United States v. Newson, 515 F.3d 374, 377-78 (5th Cir. 2008), which held that the district court may not award an additional one-level reduction under U.S. Sentencing Guidelines Manual § 3El.l(b) absent a motion from the Government and that the Government may decline to move for the reduction based on the defendant’s refusal to waive his right to appeal. Accordingly, the Government’s motion for summary af-firmance is GRANTED, its alternative motion for an extension of time to file a brief is DENIED, and the judgment of the district court is AFFIRMED.