The following excerpt is from United States v. Harris, 12-4862-cr (2nd Cir. 2013):
justice is appropriate when a defendant "gives false testimony concerning a material matter with the willful intent to provide false testimony, rather than as a result of confusion, mistake, or faulty memory." United States v. Dunnigan, 507 U.S. 87, 94 (1993). We have held that this enhancement may be imposed based on the defendant's perjurious statements where the district court makes a finding that "the defendant's statements unambiguously demonstrate[d] an intent to obstruct." United States v. Savoca, 596 F.3d 154, 159 (2d Cir. 2010).
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