What is the range of restitution available to a defendant who sexually assaulted a witness under the Victim and Witness Protection Act?

Under the Victim and Witness Protection Act ("VWPA"), 18 U.S.C. 3663, restitution may be ordered only for "the loss caused by the specific conduct that is the basis of the offense of conviction." Hughey v. United States, 495 U.S. 411, 413 (1990). The district court has broad discretion to determine the type and amount of evidence required to support an award of restitution. See United States v. Zink, 107 F.3d 716, 718-19 (9th Cir. 1997). However, "in determining the appropriate amount of restitution, the district court should not accept uncritically an amount recommended by the probation office." United States v. Barany, 884 F.2d 1255, 1261 (9th Cir. 1989). The sentencing court is responsible for making an independent determination as to the amount of loss the victim suffered as a result of the defendant's conduct. Id at 1260.