The following excerpt is from United States v. Ajoku, D.C. No. 2:08-cr-01094-WDK-5, No. 11-50230 (9th Cir. 2013):
In the context of false statement crimes, however, willfulness simply means "deliberately and with knowledge," and does not require knowledge of unlawfulness. United States v. Tatoyan, 474 F.3d 1174, 1182 (9th Cir. 2007) (citing Browder v. United States, 312 U.S. 335, 341 (1941))
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