The following excerpt is from United States v. Quatrella, 17-1786-cr (2nd Cir. 2018):
An order of restitution should not be granted that "has the effect of treating coconspirators as 'victims,' and thereby requires 'restitutionary' payments to the perpetrators of the offense of conviction," United States v. Reifler, 446 F.3d 65, 127 (2d Cir.
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