Section 1593(b)(3) (2012) (requiring a defendant to pay “the total amount of the victim`s losses” and, in addition, “the gross income or value of the victim`s services or work to the defendant, or the value of the victim`s work guaranteed by the minimum wage and overtime guarantees of the Fair Labor Standards Act”); see also In re Sealed Case, 702 F.3d at 66. This far-reaching financial responsibility reflects the general shift in the criminal justice system whereby accused are seen as individuals of immutable bad character who are likely guilty of something, even if they are not convicted in a criminal case. After the introduction of federal criminal codes, which came into effect in 1987, “relevant conduct” was always included in the calculation of a federal defendant`s applicable criminal directions.143 This “relevant conduct” includes “all acts and omissions. that were part of the same conduct, common plan or plan as the conviction offence. 144 To be considered part of a “common plan or plan,” two offences may be linked by something as fundamental as a similar modus operandi or common objective.145 “Conspiracy [and] conduct” are modern concepts that allow for greater criminal liability than acts committed by or at the direction of an individual defendant. The conspiracy law is so broad that it often eliminates otherwise necessary causal and agency links. Defendants may be liable at sentencing for the acts of a co-conspirator, including those not committed by or foreseeable by the defendant.146  Compare George, 403 F.3d to 474 (“`loss` means direct injury, not consequential harm.”); United States v. Scott, 405 F.3d 615, 620 (7th Cir. 2005) (“Most (but not all) cases dismiss attorneys` fees incurred by a victim of a crime. as “indirect damages”, which are therefore not recoverable. »); United States v.
Sablan, 92 F.3d 865, 870 (9th Cir. 1996) (indicating that follow-up fees should be exempt from the reimbursement order); United States v. Mullins, 971 F.2d 1138, 1147 (4th Cir. 1992) (“[T]he award of restitution under the VWPA cannot include consensual damages such as attorneys` and investigator`s fees spent to recover property.”); United States v. Diamond, 969 F.2d 961, 968 (10th Cir. 1992) (“Many courts have ruled that the VWPA does not approve consequential damages such as attorneys` fees and costs in connection with restitution.”); United States v. Sharp, 927 F.2d 170, 174 (4th Cir. 1991) (stating that loss of income should not be included in the restitution order); United States v. Koenig, 952 F.2d 267, 275 (9 cir.
1991) (indicating that a reward given to an informant is not a refund); and United States v. Mitchell, 876 F.2d 1178, 1183–84 (5th Cir. 1989) (expressing that there is no authority under the VWPA to authorize reimbursement of lost income or attorney fees to compensate for insurance company losses), with In re Sealed Case, 702 F.3d 59, 66 (D.C. Cir. 2012) (indicating attorneys` fees, that are reimbursed under 18 U.S.C.