The following excerpt is from United States v. Powell, 20-334-cr (2nd Cir. 2020):
15. United States v. Gushlak, 728 F.3d 184, 196 (2d Cir. 2013). Indeed, "our case law reflects the settled understanding among courts of appeals that a 'reasonable approximation' will suffice [in the calculation of restitution], especially in cases in which an exact dollar amount is inherently incalculable." Id. at 195-96 (footnote and citations omitted).
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