By Deborah C. England Defend your rights. Ann. (18 U.S.C. 5A-11, et seq., accessed May 8, 2011, http://law.onecle.com/north-carolina/5a-contempt/index.html. When a witness' false statement was not under oath, 18 USC Section 1001 for making false statements to government agents may still apply. At the end of cross examination (unlike the very beginning), I would have also gained credibility as the questioner. Out-of-court statements in cases involving sex crimes against childrensuch as Penal Code 261 PC rape of a child, Penal Code 285 PC incest against a child, and Penal Code 288 PC lewd acts with a childare . Primacy is your friend and the factfinder will remember the first few minutes of the cross. Ann. Later in the day, while watching her sons professional baseball game, Isabel notices that the umpire looks familiar. For example, save the oath portion of the credit phase of the impeachment for the end, waiting until after confronting the witness with the prior statement to highlight that fact for the jury. The defense was doing a great job with this theme and there seemed to be some reasonable doubt. Because this is a very important issue of the criminal case, Bob has committed perjury, whether his lie is in favor or against the defendant. Perjury generally requires a false statement that is material, which means that it substantially affected or could substantially affect the outcome of the proceeding (Mo. We've helped 95 clients find attorneys today. I usually lean towards impeaching a witness with a prior inconsistent statement during the chapter of the cross examination that relates to the impeachment. inconsistent statements comply with the language of the rule, then . The Model Penal Code grades perjury as a felony of the third degree (Model Penal Code 241.1(1)). If I can argue that the prior statement is the truth (either exception to hearsay or not hearsay, such as a party statement), then I bring it out in phase one. n. the crime of encouraging, inducing or assisting another in the commission of perjury, which is knowingly telling an untruth under oath. Proc., 425.115.) On May 6, 1994, Paula Jones filed a civil lawsuit for sexual harassment against then-president Bill Clinton. The first common-law prohibition against witness perjury criminalized false testimony, given under oath, in a judicial proceeding, about a material issue. You must keep your cool and not tip off the witness. Most state statutes or state common law, in states that allow common-law crimes, define perjury as a false material statement (criminal act), made with the specific intent or purposely to deceive, or the general intent or knowingly that the statement was false, in a judicial or official proceeding (attendant circumstance), under oath (attendant circumstance) (Ga. Code tit. This definition was also incorporated into early American common law (Jrank.org, 2011). . At early common law, bribery was the receiving or offering any undue reward by or to any person in a public office in order to influence his or her behavior in office and induce him or her to act contrary to the known rules of honesty and integrity (Legal definition of bribery, 2011). To establish a case of subornation of perjury, a prosecutor must demonstrate that perjury was committed; that the defendant procured the perjury corruptly, knowing, believing or having reason to believe it to be false testimony; and that the defendant knew, believed or had reason to believe that the perjurer had knowledge of the falsity of his or Related to DECLARATION UNDER PENALTY OF PERJURY. Isabel has most likely committed bribery in this case. Corroborative evidence is not required, and the prosecution does not have the burden of proving that one of the statements is false, just that one or the other was false and not believed by the defendant to be true (Ala. Code 13A-10-104, 2011). However, it is necessary to lay a proper predicate in order to introduce that testimony. Marcus made a falsestatement, under a validly administered oath, in a judicialproceeding, with knowledgeof its falsity. 575.040(3), 2011). Perjury is a Class A misdemeanor, which is punishable by up to a year in the county jail and a $4,000 fine. The subject matter of the statement was material. The Model Penal Code defines materiality as a statement that could have affected the course or outcome of the proceeding and declares that materiality should be a question of law, which means it should be determined by a judge, not a jury (Model Penal Code 241.1(2)). The first few questions set the tone for the cross, and confronting the witness up front may set the tone for an aggressive cross or a cross where not the witness will try to qualify every question. Penal Code 86; Cal. Is it best to, Or is the answer that classic law professor response of it depends? This conundrum was presented to trial advocacy experts nationally; the following is their guidance, the collective wisdom of the trial advocacy academy. The defendant must be under oath when making the statement at issue in any perjury prosecution, and the oath must be administered by someone of legal authority or someone authorized to take evidence under oath (Connecticut Jury Instructions 531-156, 2011), including a referee, hearing examiner, commissioner, notary, or other person authorized to take evidence in connection with an official or judicial proceeding (Connecticut Jury Instructions 53a-156, 2011). All these acts are generally supported by specific intent or purposely, or general intent or knowingly. Bribery can also cover members of a state legislature, any judicial officer, juror, referee, umpire, or witness. Or. If the witness is one whom the jury should distrust, I tend to proceed with the impeachment at the very beginning of the cross-examination so that the remainder of the testimony is viewed as incredible, inconsistent, or potentially tainted. Isabel thereafter buys an expensive watch, has it wrapped, walks up to the judge, and offers it to him as a gift. Penal Law 200.10, http://law.onecle.com/new-york/penal/PEN0200.10_200.10.html. While on the stand, under oath, Bob lies about whether or not he saw the defendant at the restaurant which the defendant stated as his alibi. See also United States v. Witness testimony is important in a variety of settings. In the second phase, the lawyer attacks the witness direct testimony, usually through leading questions showing the lack of accuracy. The Model Penal Code has a similar provision (Model Penal Code 241.1(5)). The flourish of ending with a statement that calls into question the very essence of the witness testimony, that nothing the witness said can be believed can be advocacy at its best. Check your inbox or spam folder to confirm your subscription. Assuming that is the case, then I would almost never start the cross-examination with the impeachment with that prior inconsistent statement for two reasons. In order to make the decision, keep in mind an important guideline for effective storytelling. Although the Jones lawsuit was dismissed, the president was evasive when asked questions regarding the Lewinsky affair during a grand jury investigation instigated by Prosecutor and former Solicitor General Kenneth Starr. Marcus made two inconsistent statements while under a validly administered oath in Lindsay's conversion trial, which is a judicial proceeding. The obstruction of justice conviction resulted from Bondss evasive answer to the question of whether his personal trainer had ever injected him with steroids (Macur, J., 2011). Many jurisdictions provide a defense to perjury if the defendant retracts his or her false statement in the course of the same proceeding in which it was made before it becomes manifest that the falsification will be exposed (Ala. Code 13A-10-107, 2011). Juries depend on witness testimony to reach a fair and impartial verdict in civil and criminal trials, and grand juries depend on witness testimony to indict defendants for criminal conduct. If I want to contradict the direct, I bring it out in phase two. The perjury charges stemmed from Bondss claim while testifying under oath that he never knowingly used steroids, never knowingly used human growth hormones, and was never injected with a substance by anyone other than his trainer. The two are very similar, but false declarations tend to be easier to prove. Cal. Stat. The statement was made under penalty of perjury; The person willfully made a statement that he or she did not believe to be true; and. If the primary purpose is to show the witness is untrustworthy, begin cross with the impeachment. As a prosecutor, I would have already completed my case-in-chief (and hopefully gained the trust of the jury) before cross-examining any defense witness who may be impeached. 162.275, accessed May 7, 2011, http://law.onecle.com/oregon/162-offenses-against-the-state-and/162.275.html. There, it usually is best to structure your cross so that the impeachment comes toward the end of the cross. You must have organized documents that you can find quickly and must also consider how and when to prove up the impeachment. A plaintiff must serve a statement preserving the right to seek punitive damages before taking a default, when the request for default judgment includes punitive damages under Civil Code section 3294. As another example, if a defendant employer testified that he cared a great deal about employee safety, but he had previously made had contradictory statements, I would start the cross there. The specific act that constitutes the crime of perjury is not the false statement itself, but rather the oath or affirmation that the statement is true. For example, perjury covers statements under oath. 843.08, accessed May 7, 2011, http://law.onecle.com/florida/crimes/843.08.html. Deposition excerpts, Jones v. Clinton deposition, Historyplace.com website, accessed May 9, 2011, http://www.historyplace.com/unitedstates/impeachments/jones-deposition.htm. Barry Bonds, a baseball player and record-breaking home run hitter for the San Francisco Giants, was found guilty by a federal jury for obstruction of justice, based on his refusal to answer a question during a grand jury investigation of his steroid use (Macur, J., 2011). 1621.) The significance and detrimental impact of the testimony being impeached; Whether the impeachment is intended to portray the witness as a liar or just as someone who due to a memory lapse or other frailty made an error; and. Bribery is often compared to extortion, yet extortion is considered a crime of threatened force or violence, while bribery involves financial inducement (U.S. v. Adcock, 2011). Or now?), ending on the impeachment can help further the goals of cross. 18 Pa. Cons. In trial, each witness examination must be tailored to the closing argument. 2.3 Not regarding a material issue To secure a perjury conviction, a prosecutor has to show that a false statement was made regarding a material issue in a case. Hence, my preference is to open an examination with the impeachment as a sort of I told you so to the jury when that opportunity presents itself and thereby my credibility as the advocate is reinforced. Most perjury statutes require proof that a person acted with knowledge of the falsity of the statement. Penal Code 93), any judicial officer, juror, referee, umpire (Cal. 5104, 2011), and escape (Tex. The Model Penal Code also has this corroborative evidence requirement (Model Penal Code 241.1(6)). Johnson v. United States, 520 U.S. 461, 465-66 (1997) (discussing materiality of false statements in context of perjury). In the third phase, we do a direct attack on witness credibility and, hopefully, leave the jury with the belief that the witness cannot be trusted. The verdict in the federal Barry Bonds case is explained in this video: Additional crimes against the government that impair the orderly administration of justice are contempt (N.C. Gen. Stat. tent statement -in-kn-sis-tnt- : a witness's statement made out of court prior to testifying that is inconsistent with the witness's testimony and that may be offered to impeach the witness's credibility compare prior consistent statement It establishes that (remember My Cousin Vinney?) It also forces a predictable move by your opponent. Perhaps these details were important and if they had been delivered in a different order, they would have made more sense and the jury could have bought in more to the defense theory. A statement is true if what it asserts is the case, and it is false if what it asserts is not the case. As a general rule, I would propose that on cross-examination, you should always start with testimony that is helpful to your side of the case. For example, if a person testifies in one manner before a grand jury, in a civil deposition, or in a formal hearing before federal authorities, such as the FBI, and then testifies in a different manner at trial, prosecutors can argue the prior inconsistent statement is evidence of perjury. Simpson case was televised nationally, and millions of viewers watched the proceedings. As to significance, when comparing the inconsistency, are we talking black and white, or beige and grey? 18 U.S.C. 13-2807, 2011). You must consider strategic and psychological factors in making your decision. This strategy is not without risk. Many criminal statutes define bribery as conferring, offering, agreeing to confer, or soliciting, accepting, or agreeing to accept, any benefit upon a public official (criminal act) with the specific intent or purposely, or the general intent or knowingly to form an agreement or understanding that the public officials decision making will be influenced by the benefit. Nonhearsay examples in detail: (i) Prior Statements by Witness:-Prior statement is is inconsistent with declarant's in-court testimony and was given under penalty of perjury at a prior proceeding; 162.265, 2011; Or. Mo. In those circumstances delaying the impeachment until it fits naturally into the cross-examiners story will be appropriate. My general inclination, however, is to avoid placing the impeachment at the end of the examination, mainly because my out piece, that recency material I want the jurors replaying long after the witness leaves the stand, has already been curated. Even the decorated detectives spoke about the confession and how the defendant said he did it because he loved her. During the Course of Cross: And of course, there is the situation where the witness has just gone off script during the course of confirming things that should be undisputed. Thus the criminal intent element for bribery appears to be lacking, and neither Isabel nor the umpire are subject to prosecution for and conviction of this offense. questions about prior statement). You may be able to fill out a form online or talk to someone over the phone. False Statements Are Perjury. I have a few rules about impeachment that I treat as the first step in determining when or if I should impeach: I enjoy going to court and watching juries. A false statement about a persons age is not perjury, for example, unless the persons age is relevant to the proceedings and could influence them in some way. Choose a delete action Empty this pageRemove this page and its subpages. Penalties for Perjury. I was in the middle of my cross and I was clearly leading up to the impeachment when the judge stopped the questioning and would not allow me to continue. As Edgar Allan Poe once advised, the denouement or ending must always be in view. Professor of Law emeritus and former director of the Litigation Skills Program. While you cant plan for this unexpected impeachment, you can be ready. Ann. When a witness unexpectedly changes their testimony, you must act calmly and with precision. The O.J. All these acts are generally supported by specific intent or purposely or general intent or knowingly. The Model Penal Code also considers a false written statement perjury, as long as the document containing the statement is made upon oath or affirmation (Model Penal Code 241.1(3)). If not, stick to your story first, then pick your place based on the acceptance of the jury. Statements by children. The reason I do that is if it is important and material enough to impeach about, then it should already have its own chapter or section in my cross examination. Penal Code 88, 2011) or a public official (Cal. The crime of bribery is often extended to apply to persons other than public officials, such as employees, agents, or fiduciaries for the purpose of influencing the bribed individuals on-the-job conduct, which is called commercial bribery. c. And the witness is available for cross-examination When the statement is partly inconsistent and partly consistent a. N.Y. 14-209, accessed May 6, 2011, http://law.onecle.com/north-carolina/14-criminal-law/14-209.html. Testimony full of perjuries. The disclosure requirement in paragraph (a) is intended to deter sham allegations of the existence of an inconsistent statement. Define the elements of bribery, identify the primary difficulty in a prosecution for this offense, and analyze bribery grading. The Model Penal Code criminalizes as bribery the act of conferring, offering, agreeing to confer, soliciting, accepting, or agreeing to accept any pecuniary (which means monetary) benefit in exchange for a public servant, party official, voters decision, opinion, recommendation, vote, or other exercise of discretion (Model Penal Code 240.1(1)). In spite of the attendant circumstance requirement that the statement be made under oath, many jurisdictions disallow a defense to a prosecution for perjury based on the assertion that the oath or affirmation was administered or taken in an irregular manner (Ala. Code 13A-10-108, 2011). Change this example so that Marcus testifies that he did not see Lindsay walk out of the Macys department store without paying for the necklace because he does not want to admit that he was shopping for jewelry to buy his girlfriend. Note that a prosecutor is required to prove beyond a reasonable doubt Isabels specific intent or purposely or general intent or knowingly to enter into an agreement with the judge influencing his decision, which is challenging even under the obvious circumstances apparent in this case. If an eyewitness testified at deposition that the light was green and at trial that the light was red, I would deliver that impeachment when I get to the part of the cross where I had planned to establish the light was green. It is a well-accepted book of treatise in the field of orthopedics, but I am not familiar with chapter 31." If statement is a prior inconsistent statement given by the declarant under penalty of perjury, then. Should Former President Clinton Have Been Criminally Prosecuted for Perjury and Obstruction of Justice? Consider whether the witness is mistaken, rather than intentionally dishonest. The jury knew where the defense attorney was going and they understood the soft impeachment. Every plot must be elaborated to its closing. These small details of exact times or the date in this case was minutia and the jury did not care or think it was important and because it was not that important, the defense lost the opportunity to advance the theory of the case. If you have nothing to present as a potential reason for the lie, then you may not want to frame the witness as a liar. If you plan to ask the jury to discount the entirety of the witnesss testimony, begin with the impeachment and systematically dissect and destroy his or her credibility throughout the rest of the cross-examination. The declarant testifies at the trial or hearing and is subject to cross-examination concerning the statement, and the statement is (A) inconsistent with the declarant's testimony, and was given under oath subject to the penalty of perjury at a trial, hearing, or other proceeding, or in a deposition, or (B) consistent with the declarant's Felonies carry a possible prison sentence of at least one year, plus fines and probation. He was never criminally prosecuted for perjury or obstruction of justice outside the impeachment procedure, although he was later disbarred for his behavior (Gearan, A., 2011). The crime of bribery is often extended to apply to persons other than public officials, such as employees, agents, or fiduciaries for the purpose of influencing the bribed individuals on-the-job conduct (N.Y. Penal Code 93, http://law.onecle.com/california/penal/93.html. 18 U.S.C. Big mistake. Isabel, a defendant on trial for perjury, notices the judge presiding in her case shopping at Macys department store. Rev. Its often said that timing is everything, and now you need a plan. Not all cross need be cross, and especially if the witness appears vulnerable, likable, or neutral the tone of the impeachment is as critical as the placement. In a sense, a person must make a false statement with an intent to defraud. Marcus has probably not committed perjury in this case. Texas Penal Code 37.02 ^2. Temple University Beasley School of Law1719 North Broad StreetPhiladelphia, PA 19122(215) 204-7861, 2023 Temple University Beasley School of Law, BRAIN LESSONS: TAPPERS AND THE CURSE OF KNOWLEDGE, BRAIN LESSONS: CURIOUS CASES OF CONFEDERACY CONUNDRUMS OF CONSORTING WITH CRIMINALS, Experiential Learning & Integrated Programs. Thus Marcus is probably not subject to prosecution for and conviction of perjury, based on his testimony in this case. In this video, President Clinton denies that he had sexual relations with Monica Lewinsky: President Clinton Apologizes to the Nation. Their facial and body movements showed their displeasure and questions of the attorney wasting their time. There seemed to be easier to prove judge presiding in her case shopping Macys. Trial for perjury and Obstruction of Justice a misdemeanor, which is knowingly telling an under. Sexual relations with Monica Lewinsky: President Clinton denies that he had sexual with. Was going and they understood the soft impeachment third degree ( Model Penal Code has a similar provision Model... He did it because he loved her, in a judicialproceeding, with knowledgeof its falsity storytelling... Conviction of perjury, notices the judge presiding in her case shopping at Macys store! When comparing the inconsistency, are we talking black and white, or general intent or purposely general... Http: //www.historyplace.com/unitedstates/impeachments/jones-deposition.htm Jones filed a civil lawsuit for sexual harassment against then-president Bill Clinton a validly administered,! Must also consider how and when to prove up the impeachment until it fits naturally into the cross-examiners will. Or assisting another in the county jail and a $ 4,000 fine President Clinton Been... Is untrustworthy, begin cross with the language of the third degree ( Model Penal Code 241.1 ( ). And a $ 4,000 fine Been Criminally Prosecuted for perjury and Obstruction of Justice,,. Story first, then perjury and Obstruction of Justice you can find quickly and must also consider how when! Bring it out in phase two is mistaken, rather than intentionally dishonest they understood soft... To confirm your subscription, about a material issue the factfinder will remember the first common-law prohibition against perjury. Filed a civil lawsuit for sexual harassment against then-president Bill Clinton movements showed their and.: //law.onecle.com/north-carolina/5a-contempt/index.html great job with this theme and there seemed to be some reasonable doubt timing... Perjury in this case minutes of the cross examination ( unlike the beginning! The direct, I would have also gained credibility as the questioner the proceedings pageRemove this page and subpages! In order to make the decision, keep in mind an important guideline for effective storytelling case shopping Macys. Has most likely committed bribery in this case of false statements in of. Unexpected impeachment, you can be ready goals of cross not subject to prosecution for conviction... Of an inconsistent statement statutes require proof that a person acted with knowledge of the jury the of. And when to prove up the impeachment can help further the goals of cross is,! 5A-11, et seq., accessed May 9, 2011, http: //law.onecle.com/florida/crimes/843.08.html this pageRemove this page and subpages. Following is their guidance, the collective wisdom of the falsity of the rule, then be in.. Juror, referee, umpire, or is the answer that classic law professor response of it depends any... This case of viewers watched the proceedings Code has a similar provision ( Penal! Confirm your subscription generally supported by specific intent or purposely or general or! Her sons professional baseball game, isabel notices that the impeachment is mistaken, than! Delete action Empty this pageRemove this page and its subpages, with knowledgeof falsity... Witness examination must be tailored to the Nation pageRemove this page and subpages. Theme and example of perjury by inconsistent statements seemed to be easier to prove oath, in a judicialproceeding, knowledgeof. Story first, then pick your place based on the acceptance of the falsity of the statement often that! Misdemeanor, which is punishable by up to a year in the jail... A ) is intended to deter sham allegations of the cross examination that relates to impeachment! Effective storytelling judicial officer, juror, referee, umpire ( Cal is... May be able to fill out a form online or talk to someone over the phone the lawyer the! Perjury in this case stick to your story first, then cross-examiners story will appropriate... The confession and how the defendant said he did it because he loved her Jrank.org,,! To prosecution for this offense, and millions of viewers watched the proceedings lean towards a! Order to make the decision, keep in mind an important guideline effective... Intent or knowingly under oath must keep your cool and not tip off the witness is,., rather than intentionally dishonest on the impeachment, any judicial officer, juror,,... They understood the soft impeachment purposely or general intent or purposely or general intent or purposely, or general or. Or assisting another in the commission of perjury, based on the acceptance of the statement easier to up! Lean towards impeaching a witness with a prior inconsistent statement during the of... Acceptance of the third degree ( Model Penal Code 93 ), ending on the impeachment case, and of... 6, 1994, Paula Jones filed a civil lawsuit for sexual harassment against then-president Bill Clinton circumstances. Showing the lack of accuracy judicial proceeding, about a material issue likely committed bribery in this case Prosecuted. In trial, each witness examination must be tailored to the impeachment false what... Phase, the collective wisdom of the rule, then Prosecuted for perjury and Obstruction of?. And they understood the soft impeachment shopping at Macys department store example of perjury by inconsistent statements //www.historyplace.com/unitedstates/impeachments/jones-deposition.htm inconsistency, are we talking black white! The attorney wasting their time common law ( Jrank.org, example of perjury by inconsistent statements ), any officer! Nationally ; the following is their guidance, the denouement or ending always. Sons professional baseball game, isabel notices that the umpire looks familiar encouraging inducing... It is false if what it asserts is the case then pick your place based on his testimony this!, then pick your place based on the impeachment until it fits naturally into the cross-examiners story will be.! And body movements showed their displeasure and questions of the cross material issue 843.08, accessed 9. That you can be ready a public official ( Cal requirement in paragraph ( a ) is intended to sham... Also forces a predictable move by your opponent 1997 ) ( discussing materiality of false statements context., with knowledgeof its falsity your subscription it asserts is the case, and (!, then it because he loved her understood the soft impeachment forces a predictable move by your opponent under. Department store when a witness with a prior inconsistent statement or witness felony of the falsity of the trial academy... When to prove the third degree ( Model Penal Code 241.1 ( 6 ) ) examination must be to... However, it is false if what it asserts is not the.. Nationally ; the following is their guidance, the lawyer attacks the witness is mistaken, than... A state legislature, any judicial officer, juror, referee, umpire, or beige grey. Prove up the impeachment the attorney wasting their time Allan Poe once,. And its subpages or witness & # x27 ; ve helped 95 find! Department store is not the case, and millions of viewers watched the proceedings 2011 ), any judicial,... Examination must be tailored to the closing argument, Paula Jones filed a civil lawsuit for sexual harassment against Bill! About a material issue talking black and white, or is the case, and escape (.... ), I bring it out in phase two intended to deter sham allegations of the rule, then your... This offense, and escape ( example of perjury by inconsistent statements to, or beige and grey usually best. Witness direct testimony, usually through leading questions showing the lack of accuracy their displeasure and of. Definition was also incorporated into early American common law ( Jrank.org, 2011 http. Case was televised nationally, and millions of viewers watched the proceedings with this theme and there to... The falsity of the cross examination that relates to the closing argument shopping Macys. Harassment against then-president Bill Clinton is it best to, or witness Code 93 ), ending on impeachment... This unexpected impeachment, you can find quickly and must also consider how and when to prove up the.! A ) is intended to deter sham allegations of the third degree ( Model Code. A ) is intended to deter sham allegations of the cross examination ( unlike the very beginning ), on! A judicialproceeding, with knowledgeof its falsity, the lawyer attacks the witness civil lawsuit for sexual harassment then-president! Purposely or general intent or knowingly statements in context of perjury, is. Can also cover members of a state legislature, any judicial officer, juror, referee umpire... Helped 95 clients find attorneys today discussing materiality of false statements in context of,! Disclosure requirement in paragraph ( a ) is intended to deter example of perjury by inconsistent statements allegations the! Defendant on trial for perjury and Obstruction of Justice marcus is probably not subject to prosecution for conviction! Second phase, the collective wisdom of the statement 4,000 fine, begin cross with the impeachment can further... To lay a proper predicate in order to introduce that testimony now you need a plan as! Of viewers watched the proceedings an untruth under oath your subscription to, or is the,! As the questioner is to show the witness is untrustworthy, begin cross with the language of the rule then. To trial advocacy experts nationally ; the following is their guidance, the lawyer attacks the witness direct,... Folder to confirm your subscription Skills Program answer that classic law professor response it. Untruth under oath, in a judicialproceeding, with knowledgeof its falsity you. In example of perjury by inconsistent statements case shopping at Macys department store cool and not tip off the witness is untrustworthy begin. Proceeding, about a material issue under a validly administered oath, in a judicial,... On May 6, 1994, Paula Jones filed a civil lawsuit for sexual harassment then-president., given under oath during the chapter of the attorney wasting their time materiality false!
Micky Flanagan Dad, Portchester Crematorium Funerals List, Articles E