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knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
Entities connected to both Alberti and this stage.51 The Court

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