Combined sentencing discounts for guilty plea, assistance to authorities, and voluntary disclosure of guilt (Ellis factor) exceeding 40% should be exceptional in the absence of evidence that the offender will serve the sentence in more onerous conditions. The allocation of a discrete Ellis discount is likely to result in error; voluntary disclosure of otherwise unknown guilt should be treated as part of the overall assessment of cooperation and subjective case rather than as a separate quantified discount. Where multiple discounts are applied, the sentencing judge must make clear whether they are applied in combination or sequentially, as the methods produce different outcomes.
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