Cumulative sentences must be structured with a base sentence to which cumulation orders attach; failure to do so is not a mere matter of form but a substantive error that may result in inappropriate sentences and will require re-sentencing on appeal. General deterrence remains a significant sentencing consideration in cases of employee fraud involving breach of trust, even where the offender has no prior convictions and the offending is attributable to self-destructive conduct following personal setbacks.
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