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CRM 1500-1999

1762. Perjury Cases -- Sample Indictment -- 18 USC 1621 (first Paragraph)

  1. On or about the ______ day of ________________, 19__, in the ________________ District of ________________, JOHN DOE, having duly taken an oath, before the Securities and Exchange Commission, a competent officer of the Commission during an investigation duly authorized by the Commission, a case in which Title ________, U.S.C., Section _____________ authorizes an oath to be administered, that he would testify truly, did willfully and knowingly and contrary to said oath state material matter which he did not believe to be true, that is to say:
  2. At the time and place aforesaid the Commission was conducting an investigation into the practices and financial conditions of the XYZ Corporation to determine whether said corporation had violated Title ________________, U.S.C., Section ____________. It was material to the aforesaid investigation to determine whether JOHN DOE had ever borrowed money from the XYZ Corporation.
  3. At the time and place aforesaid in paragraph 1, JOHN DOE appeared as a witness before the commission, and then and there being under oath as aforesaid, testified falsely before the Commission with respect to the aforesaid material matter as follows:
    • "Q. Have you ever borrowed money from XYZ Corporation? A. No."
  4. The aforesaid underscored testimony of JOHN DOE, as he then and there well knew and believed, was false in that on January 13, 1974, JOHN DOE did in fact borrow money from the XYZ Corporation.

All in violation of 18 U.S.C. Sec. 1621.

[cited in JM 9-69.200]