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1764

Perjury Cases—Sample Indictment—18 USC 1622

  1. On or about the ______ day of ____________, 19__, in the District of _____________, the defendant, ____________________, did willfully suborn and procure one RICHARD ROE to commit perjury by testifying falsely under oath to a material matter in a case entitled _____________v.____________, No._____, in the United States District Court for the ___________ District of _______________________________.

  2. It was material to the said case described in paragraph one to determine whether JOHN DOE had ever made a loan of money to the said RICHARD ROE.

  3. The defendant ______________, on or about the _____________ day of ___________, 19__, willfully suborned and procured RICHARD ROE to testify falsely in the proceedings described in paragraph one that JOHN DOE had never made a loan of money to RICHARD ROE; and on the _________ day of ___________, 19__, the said RICHARD ROE falsely testified under oath in the proceedings that JOHN DOE had never made a loan of money to the said RICHARD ROE.

  4. The testimony of RICHARD ROE as aforesaid was false and perjurious as both RICHARD ROE and the defendant well knew.

All in violation of Title 18, U.S.C. § 1622.

[cited in USAM 9-69.200]