and the letter from the Department to the Sentencing Commission ... [the] brief controls and [the] brief represents the official position of the Justice Department on this issue in the case of people like the ones here who have their money stolen from their accounts by debit and who from our perspective do suffer [a] pecuniary harm, albeit it a temporary one.” 13 . Other circuits that have found that temporary losses do not constitute actual pecuniary harm and do not bring their bearers within section 2Bl.l’s definition of "victim” have nonetheless concluded that secondary financial harms, such as the cost of time spent seeking reimbursement, can render reimbursed individuals "victims” within the meaning of the guideline. See United States v. Abiodun, 536 F.3d 162, 169 (2nd. Cir.2008) (<HOLDING>); Pham, 545 F.3d at 721 (same). In addition to
holding that the cost of time spent seeking reimbursement can render reimbursed individuals victims within the meaning of section 2b11 so long as time cost losses are included in the subsection b1 loss calculation holding that the district court was correct in dismissing the section 1782 application as moot because at that time there were no foreign proceedings within the meaning of the statute in which the discovery could be used holding that the plaintiff could not recover fees for time spent on unsuccessful motions holding time spent on electronic monitoring while on bail release does not constitute custody within meaning of sentencing credit statute holding that the relevant time is the time of the employment decision