OPINION
PAEZ, Circuit Judge:
At common law, a person could be convicted of perjury "when, under oath, he wilfully and corruptly [gave] false testimony on a material point in a judicial proceeding." 4 Wharton's Crim. Law § 574, Westlaw (database updated Sept. 2015); see also In re H____, 1 I. & N. Dec. 669, 670 (BIA 1943...
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