Did the District Court clearly err in applying a four-point 'vulnerable victim' enhancement under U.S.S.G. § 3A1.1(b) to defendant's sentence, absent a showing that the victims were 'unusually vulnerable'?

QUESTIONS PRESENTED FOR REVIEW 1. Did the District Court clearly err in applying a four-point “vulnerable victim” enhancement under U.S.S.G. § 3A1.1(b) to defendant’s sentence, absent a showing that the victims were “unusually vulnerable”? More generally, does this criminal sentencing enhancement require a showing that the victims were “unusually vulnerable” in order to apply? 2. Did the District Court clearly err in applying a two-point enhancement for “conscious or reckless risk of death or serious bodily injury” under U.S.S.G. § 2B1.16(b)(16), by applying the objective test for “reckless” established in the Second Circuit in United States v. Lucien? More generally, does this criminal sentencing enhancement require the courts to use an objective or subjective concept of “reckless”? it} STATEMENT OF