The following excerpt is from People v. Loizides, 123 Misc.2d 334, 473 N.Y.S.2d 916 (N.Y. Cty. Ct. 1984):
Failure to charge corroboration in the context of a perjury prosecution to a grand jury has been held to be a substantive denial of due process. People v. Mackey, 82 Misc.2d 766, 770, 371 N.Y.S.2d 559. Further, the failure to provide the requisite corroboration by the grand jury constitutes insufficiency as a matter of law. People v. Pawley, 71 A.D.2d 307, 423 N.Y.S.2d 69.
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