This legal document is a court filing that refutes two arguments made by the defendant. First, it argues that the standard for the victim's (Carolyn's) behavior is 'undue influence,' not complete lack of voluntary action. Second, it dismisses the defendant's claim of 'double-counting' in sentencing enhancements by citing legal precedents (Watkins, Kohlmeier, Arbaugh) which establish that different guideline provisions can address different harms from the same conduct.
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