U.S. v. Burkholder, No. 08-50446 (1-8-10). Must victims' letters be attached to the PSR? In this victim's rights case, the 9th finds no violation of either the Crime Victim's Rights Act or of Rule 32 in the removal of victim impact letters from the PSR. The victims' had their views considered, and neither the Act nor Rule 32 required that the impact letters be attached. Indeed, the court found that the letters contained conduct unrelated to the defendant.