- 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 _______________________________.
- 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.
- 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.
- 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 JM 9-69.200]