The following excerpt is from United States v. Graham, No. 14-4037-cr (2nd Cir. 2015):
multiple 2B3.1 sentencing enhancements for physical restraint and injury to victim where conduct found to "facilitate, as opposed to constitute" offense); accord United States v. Sabhnani, 599 F.3d 215, 251 (2d Cir. 2010) (stating that "[m]ultiple adjustments are properly imposed . . . when they aim at different harms emanating from the same conduct" (internal quotation marks omitted)).
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