A very substantial discount for a co-offender's assistance to authorities is more commonly warranted where there has been a high and extended degree of assistance in solving criminal activity or where the offender gives very important evidence in challenging circumstances; a 23-page statement implicating a co-offender, while significant, did not warrant a discount producing a 40 per cent disparity in total effective sentences. The Crown's obligation to submit an appropriate sentencing range under MacNeil-Brown will only benefit the sentencing process where the range is appropriate, sufficiently broad, and accompanied by informative justification.
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