MEMORANDUM
VANASKIE, District Judge.
Defendant Theresa Lamplugh has been indicted for, inter alia, making false declarations in violation of 18 U.S.C. § 1623. (Dkt. Entry 105, Count 23.) In pertinent part, count 23 alleges that defendant Theresa Lamplugh made "false material declarations under penalty of perjury" when she submitted a "declaration" in support of a motion for the return of property...
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