A sentencing judge who identifies all factors relevant to objective seriousness under a heading of 'Objective Seriousness' has not failed to discharge the duty to assess objective seriousness, even without using a specific adjective or descriptor to characterise the level of seriousness. Trading one illegal substance for another illegal substance will very often represent more significant criminality than trading an illegal substance for money, justifying a degree of notional accumulation in aggregate sentencing.
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