Legal Case Summary

We'll start with the United States versus Asheville. Okay. Good morning. Good morning. Good morning. The mayor police of court, my name is Anthony Zorke. I represent the government in this case and the government that's being held. There's two major positions that have been held. I was asked to resort about two minutes for a bottle of space. Okay. Question raised in this appeal is whether a material false statement made an immigration document and presented immigration authority must be made under oath or penalty of perjury to be a violation of Section 1546A. The government submits that it does not that the presentation alone of the immigration paperwork knowing that it contains material false statements is sufficient. We have to look at the statute. Absolutely. We have to ask that you have. The defendant and the defendant send the district court to disagree the government's position. The government's position is supported by the text and the structure and the purpose of the statute. We just not said clear. We just not decided to give it clear. But as this court has said almost every statute has some ambiguity in it. Well, kind of it doesn't get out of the screen when you are in the statute, but I'm not sure that I would say every side. That's a strong statement. Go ahead. Especially for the government to make

. We're not asking for the third circuit. No, for me. The government's position is also supported by the case and the second circuit and by the statutory history. I don't see just the misguided. The first thing I asked the court to look at is the purpose. It was a, it was a, it's not a sign looked at up. It's not a sign opinion. It's a court of courier. I just second circuit. I want to know. You are a legal lawyer. You can't approve of some statute. The language of the statute is critiqued. Absolutely. Okay. And then you have a section there. And you say such refers only to half of what precedes it. Under statute to a construction, how can you say a such can pick out what it refers to? Well, you're right. I think what you have to do when you look at that language. There are two uses of the right quality, the very such as in that section. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement

. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. To be consistent in this statute. To be consistent in this statute. This is where I had to tell you. I had to tell you. I kept my cake to you

. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you

. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. It's a perfect example of Congress and the birthday of Nathaniel and Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall

. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. What I may ask him is how do you look at this on the first or second reading and understand that if I decide to start to get an intern it over to a school, I may be subject to theory as a prison, if that state ends up in jail. I just want to talk a bit about the document that was contained in the glass. I think that I would like to say- Everybody agrees. I think we agree. I think we agree. I think we agree. If not, it isn't true. Yes, Your Honor. But I don't question Dutch Frances

. asks, does that make a difference? I'm sorry. It didn't, too. It did not intend to stay in a full course, etc. Well, I think you'll look at what we're taking and what's in the facts of this case, and you'll just look at the statute and then go back to the judge's initial heart and the initial statement, how do you know what should do you get wrong? I think most people are looking at the facts of this case, most people are going, if they lie, and the government that gives us a government that government who lies on, they get something back from it, that's wrong. I can make a misread. You know, I don't know if it's me. But what's the true about it? Then he said that, that he attended the program for excellent number of hours and... He intended to, he intended to, but he realized that they were showing video movies at this program and it really wasn't the program. It really changed his seat. Well, let's say he has a misrepresentation because he wasn't going to require any number of hours per day. Is there something Jay could tell me that if that statement was wrong, and he submitted to the schooling that it presented for 10 years? You're on our first wall. The one that's as offended as we've got for a certain amount of hours, he's going to get all, what would he be doing? But he was black, he wasn't, what would he be doing? Well, he said he was doing other things, what would he be doing? I'm trying to get a picture of him again. There he is. I'm telling you, the statute, and it's kind of, when I see it, it fits. The only problem is understanding what this says on the first or second reading, and I just think it's impossible. Well, I'm going to go try to make this right now, and I'm afraid to make this right now. I don't really look for it to people in this room that would know the same. God, I don't want to disagree with you that when the first reading a statute it takes some time to go back over and read it. But I think when you look at the purpose of the statute, when you look at the statutory history in this case, then we look at the language of it, and I didn't complete that last section of it, but when you look at the, such as the, or as the fourth statement, you go back and it should be in the same world and the fourth statement, and it follows it, which in this case is material of course. So I see the, as to the East of the language, I suggest that the defense's argument is formed. As to the purpose of the statute, when you look at the entire statute, all four paragraphs, you find that God was cruel and was intended to prohibit all four-general action-going immigration documents, they prohibit the four-gen caliphate and both were falsely making others and using possessing a ten-general sect of accepting, receiving the immigration documents and on the fourth caliphate, falsely making the first statement, and on the bottom, and then you get to this part where you say, well, they must have not had in their concentration as someone who presented a document of wise and at false statements that they're going to lie on, but that would be a lie

. He was originally charged with making a statement under mouth, wasn't it? And then why was that changed? You're not allowed to interpret, or should the trial have looked at, otherwise that would have been blinded. It's part of the argument. Confused by the statute. Confused by the statute? Confused that was just, I don't know. I was just a little sad. I don't know what I was saying. They had to be invited to conform with your review, and I decided to leave the statute. Well, I'll tell a bit more closely, I sure. But if you wanted to get this guy for making a small statement under statement under your own, for his false, you could, because he did. You just picked the wrong document. There was, well, the big event would go back to the original documentation. I must surely still be statute of that, but I think you probably would have been close. So this was the most applicable one, and I'm sure you've been wondering how to prevent this one, because as I quoted here earlier, it's not something that makes the false statement, but at the time he makes the statement, how can you show that he intended the default to go? In this case, we had him not going to classes of all, not paying tuition, but we're going to have a job. How do you do the classes, sir? Not for the one equal, but for January 22, 2010, until June 20, 2010, came in with 10 more requests. And you can kick him out of the country anyway, right? That's the right thing, right? Yes, that's true. I'm going to ask the court to look at the statute or the history of case that perhaps this is the most important factor since the court has not really, I would have been able to indicate that they're going with the classes of all of the statute. But then take what we asked in the court. I apologize. I mean, we know that's our job to press you. Could she sit with our job? Yes, the help card is in the current presenter. It will be the mayor of a document that is under a false form. He can be a presenter of a document that contains materially false statements. He presented it to the official open school back in the summer

. He's like, I don't know. Official at that one. The quasi-government. Well, she's representing the government in this program, the Seifers program. Just that in government. No, she's not crying. And she's acting in a place that government that put in. Is she implicit that in documentation she gets into a computer system? Yeah, I don't have a basis for that. And what is there is there a basis for confirming that? She is, in fact, the government of the issue. She's not a government official, though. Well, she acts instead of the government. I mean, she, there are no, she, she to plot, takes the information he gives. She implicit into a computer and that goes to New York. Because she has the same. I see in the paper work. Yes, sir. And his presenting a document that contains a file statement is the act that's adjacent to the criminal penalty. Yes, sir. How often does the government prosecute people for unsworn statements? I never think I've ever seen it. Not been in 34 years. Well, I've seen it. I only have 18 years long, and I can't answer that question. You're so kind of uncertain

. Question, does it hurt? Yeah, when you do your tax return, you get your fake. It goes to somebody who nets somebody files a foreign with the government, but there's a provision at the, above your signature that says, sir, the here is not true or in trouble. Well, at least he gives her a form. And she also swears under a number of penalty encouraging the virtue of the correctness. But there was nothing in the document that he submitted that would alert him that if anything in the document itself, it's false. He would be subject to criminal penalties. He said that he's certified that the state is a true or correct, he's certified according to the, to the, to the, there's a certification in the document that he signed. Yes it was. OK. Just saying that I certified the state is a true or correct. OK, that's different from an oath. Yes, it's different. Isn't the statute at least ambiguous? I look at what we're, we're going through. I look at the papers that have been written. And if it was ambiguous, are we required to pardon more than anything? You're on the, what the court has said in the past is that the third circuit said after the one accounts. Yes. And he said, if, if after considering the tax structure of history of the statute to remain a group and a community, or on the circuit of the statute, then, then the rule of any apply. And she's, through his own say, doesn't apply, only there's a mere, see, this is what I said, or the mere suggestion around the community, because most statutes are ambiguous to some degree. So, and I just, well said, she didn't say that. It's about it. And I expect that in the, in my very often, but I expect that in front of the court oftentimes, the argument is, oh, the statute, what it means. And what doesn't mean. That's what I mean

. That's what I'm just, that's what I am. That's what you're saying. OK. OK. What are you on the bottle? Good morning, ladies and gentlemen. That's why Senator Lucas Henders here represents Derracheol today. Mr. Schmeitzer, he obviously applied. It's obviously, it's close. Why doesn't the government have the right to say, you know, you want something from us, you want a visa, who gave us a first document. We're not going to accept that. We're not going to let you get away with that. Why isn't the government entitled to that? Well, because there's no doubt that the fourth paragraph of 1546 focuses on those. It puts out the very old requirement. The issue is, does it, does it, is it limited somehow to the makers, the making laws of the pathetic law? And I'm submitting Derrach to background critical facts here, which really go to your owners' question and show that there's no problem with the defense reading the statute, the appropriate reading the statute. One is that, again, the oath requirement is the very first statement mentioned in session four. We get the paragraph four. We get the, it's okay, this is about the statement, the false statement is the number of. Those are the report statements, those are the most culpable statements. But he knew it wasn't correct. Well, we were on the respect to the judgment panel and the court had actually been in the wrong table. And the court had been on the first count again, convicted on the second count, and they had found you were at the student level. But in the scheme of four things, for the last minute here, it's been total control of what is the statement. So, it's been total control of the whole criminal section? No, you're right. I would say you're more precise. It makes the immigration forms. It provides, it requires whatever indienes which ever states it deems the most critical to immigration enforcement, that it was important, that it was material, why am I, it imposes the law. So, there's other issues before, if they want to. The government can change the form. So, you know, with those two, that... I think this is after the second circuit opinion. What does that mean? Which language one against the government? Well, the scientific opinion actually held that the American economy doesn't apply with respect to the presentation. However, in fact, this is never been cited. It's sort of out there in 30 years. Well, this doesn't come up that often. That's what I... I'm not sure, I think it's because the government... This isn't a big problem. The government wants the forms. The government specifies which things are to be sworn which are

. So, it's been total control of the whole criminal section? No, you're right. I would say you're more precise. It makes the immigration forms. It provides, it requires whatever indienes which ever states it deems the most critical to immigration enforcement, that it was important, that it was material, why am I, it imposes the law. So, there's other issues before, if they want to. The government can change the form. So, you know, with those two, that... I think this is after the second circuit opinion. What does that mean? Which language one against the government? Well, the scientific opinion actually held that the American economy doesn't apply with respect to the presentation. However, in fact, this is never been cited. It's sort of out there in 30 years. Well, this doesn't come up that often. That's what I... I'm not sure, I think it's because the government... This isn't a big problem. The government wants the forms. The government specifies which things are to be sworn which are... The government can charge. They could charge the one 15th, the one 15th of I-19. Excuse me. What is that? Is that out of the statute of limitations? Or is it still? I had to work out the date, but no, the statute's to conform to the relevance, you know, how it's looking in charging. Maybe they should charge earlier, who knows? They could have charged on to the digital culture, meaning they could have charged... So they could have charged on to the rationality presenting the secure state that was under arrest. So, once you understand this, you can see that there isn't a free car. It can never afford. And the government can prove that both anytime they want, that both the government and the doctors, anytime they want. The only thing the only sensible in the statute is that sworn statements, important statements, that's going to need to come from liability, once sworn statements are not relevant. And Jeff Sauer, when he was talking about it, he would only present to you a document that could date a falsehood. And that's the government's interpretation. Well, it's unreasonable about imposing penalties and somebody that, consistent with the reason that he's trying to preserve makes a false statement to be official. Well, it is, like, a reasonable for the government to write an over-carbon signature in the right unreasonable for the government to say that the oath required doesn't apply to the present. The doctor, that no one thinks false. And what a problem with that is, it's too false. It needs to tell the attorney that it was all too late. And it needs to be just a false description. Stop there and tell us why it's totally all the truth

... The government can charge. They could charge the one 15th, the one 15th of I-19. Excuse me. What is that? Is that out of the statute of limitations? Or is it still? I had to work out the date, but no, the statute's to conform to the relevance, you know, how it's looking in charging. Maybe they should charge earlier, who knows? They could have charged on to the digital culture, meaning they could have charged... So they could have charged on to the rationality presenting the secure state that was under arrest. So, once you understand this, you can see that there isn't a free car. It can never afford. And the government can prove that both anytime they want, that both the government and the doctors, anytime they want. The only thing the only sensible in the statute is that sworn statements, important statements, that's going to need to come from liability, once sworn statements are not relevant. And Jeff Sauer, when he was talking about it, he would only present to you a document that could date a falsehood. And that's the government's interpretation. Well, it's unreasonable about imposing penalties and somebody that, consistent with the reason that he's trying to preserve makes a false statement to be official. Well, it is, like, a reasonable for the government to write an over-carbon signature in the right unreasonable for the government to say that the oath required doesn't apply to the present. The doctor, that no one thinks false. And what a problem with that is, it's too false. It needs to tell the attorney that it was all too late. And it needs to be just a false description. Stop there and tell us why it's totally all the truth. Because it's on the government's reading. Okay, well, there's an un-sourced statement. If the person who makes that statement submits it to the government, that is a non-climbed, but it's even the government that admits that there's no both requirement for someone who makes a statement. But we always do defend it instead. It's said to go into this position, as I understand it, to be the government, it says, we're representing the document that contains a false statement with respect to a material fact that doesn't require the agreement. And that's what it says as a as-rock English case, that they should be. That's correct or not, I don't know. Just letting it particularly happen. I think it does address your point. The issue is too high, we see it get to that. The government, we'll talk about that in a second, but the government says... Is that for the judges? The government says that this bill for you are applying to seek is made by the person and submitting it in a form. But it doesn't apply with the person presently in a presenter, you know, the person who presents the form. It doesn't apply that contestation, or if you're pardoned for presenting it, so let that be announced. What does that make any sense by the way? It doesn't make any sense, because it makes sense. So I mean, why would Congress have done that? I would say, it doesn't make sense to draw the line of criminal life that will lead to some makers and quote-makers and quote-presenters. But Congress did it. Well, the statute that emits a lot. The statute of rules does that, and it makes a lot. Well, no, it does. But the question is, what does the oath of requirement apply to the Department of Health or does it apply to one? So I would suggest to your honest that the critical point here is that it has some piece of statement and gives it to the government

. Because it's on the government's reading. Okay, well, there's an un-sourced statement. If the person who makes that statement submits it to the government, that is a non-climbed, but it's even the government that admits that there's no both requirement for someone who makes a statement. But we always do defend it instead. It's said to go into this position, as I understand it, to be the government, it says, we're representing the document that contains a false statement with respect to a material fact that doesn't require the agreement. And that's what it says as a as-rock English case, that they should be. That's correct or not, I don't know. Just letting it particularly happen. I think it does address your point. The issue is too high, we see it get to that. The government, we'll talk about that in a second, but the government says... Is that for the judges? The government says that this bill for you are applying to seek is made by the person and submitting it in a form. But it doesn't apply with the person presently in a presenter, you know, the person who presents the form. It doesn't apply that contestation, or if you're pardoned for presenting it, so let that be announced. What does that make any sense by the way? It doesn't make any sense, because it makes sense. So I mean, why would Congress have done that? I would say, it doesn't make sense to draw the line of criminal life that will lead to some makers and quote-makers and quote-presenters. But Congress did it. Well, the statute that emits a lot. The statute of rules does that, and it makes a lot. Well, no, it does. But the question is, what does the oath of requirement apply to the Department of Health or does it apply to one? So I would suggest to your honest that the critical point here is that it has some piece of statement and gives it to the government. Under the government's view, that unswore statement is what's working out. Unswore statement under the government's view, no crime. But if that same person makes the same oneswore statement, it takes it to a equivalent of attack, curb-per-region service, or has someone presented all the sudden has a crime. And that makes no sense. It makes no sense. Why criminal liability would turn on? Who he is to go? Who he is to the government? The document to the government. Now, just one case, with respect to your point, now, presentation, I think it's an excellent one. I think that the Friday, which I would be, was held in the brief. There's an alternative basis here, the firm, which is the differential of, isn't just the assumption of, it's efficient since it's trash off, is not the percent of all. The DSO, the state, is a presently in the sense of currently in the document. But I had had some questions about that, and that may represent the governor. So that may be subject to the statute. And I won't think it will be. I have a free presentation under the statute, must be intended to the government, it's an integration document. Now, this testimony was perfectly clear from the government's what this is the experts in this program brought in from a place they said, a student cannot access that database. The submission to the government happens by the school official, to school official, put it into the computer database, and that's what happens. So I do believe, if the court might climb that, that sort of thing, that's a really, really, really, this issue. Now, I would like to show, you're on this cover, you can't see. But this is one more cup of the statute. Full cover, circles, arrows, everything has a spectrum. And you're on this, maybe that's something similar. When you go back to the statute, statutory construction, you've got a such. And what is the such referred to? To me, I find it difficult to conceive how you can pick and choose any such, when you talk about, present any such application

. Under the government's view, that unswore statement is what's working out. Unswore statement under the government's view, no crime. But if that same person makes the same oneswore statement, it takes it to a equivalent of attack, curb-per-region service, or has someone presented all the sudden has a crime. And that makes no sense. It makes no sense. Why criminal liability would turn on? Who he is to go? Who he is to the government? The document to the government. Now, just one case, with respect to your point, now, presentation, I think it's an excellent one. I think that the Friday, which I would be, was held in the brief. There's an alternative basis here, the firm, which is the differential of, isn't just the assumption of, it's efficient since it's trash off, is not the percent of all. The DSO, the state, is a presently in the sense of currently in the document. But I had had some questions about that, and that may represent the governor. So that may be subject to the statute. And I won't think it will be. I have a free presentation under the statute, must be intended to the government, it's an integration document. Now, this testimony was perfectly clear from the government's what this is the experts in this program brought in from a place they said, a student cannot access that database. The submission to the government happens by the school official, to school official, put it into the computer database, and that's what happens. So I do believe, if the court might climb that, that sort of thing, that's a really, really, really, this issue. Now, I would like to show, you're on this cover, you can't see. But this is one more cup of the statute. Full cover, circles, arrows, everything has a spectrum. And you're on this, maybe that's something similar. When you go back to the statute, statutory construction, you've got a such. And what is the such referred to? To me, I find it difficult to conceive how you can pick and choose any such, when you talk about, present any such application. The letter it normally makes under oath, any full statement with respect to the material fact in any application. Or knowing you present any such application. It seems to me that any such application has to include making it under oath and being material. And how do you just say, I'll refer to that thing and not to that thing. I think you're absolutely right on. What we have to do is we have to look back. That's a common way to address something, especially, we have requirements, we already have 150 words in the sentence. So we're going to say any such. And you have to look back. What is the sense of a referent of that any such? If you can't, clear after the reference to section 1746, it makes it a lot easier to understand. It doesn't. And I sort of condensed it in my brief just for that reason. Because, finally, you know, I just, I had this case, I was possibly over the discussion still into that. So, you know, I think at the end of the day here, you know, sort of, you know, I see how it can be. I'm going to be for sure. I mean, even if... Well, they try. Things they do, they do, they do, are the same for many. It is after we've only called the standard technique, especially to reconstruction text, structure, legislative history of the class, grammar, everything. Then, if the court feels it's left with essentially guesswork, then the name must apply is the court must, you know, just very recently, in the subordinate case. That was the whole thing in that case, and the referent being court of the monity

. The letter it normally makes under oath, any full statement with respect to the material fact in any application. Or knowing you present any such application. It seems to me that any such application has to include making it under oath and being material. And how do you just say, I'll refer to that thing and not to that thing. I think you're absolutely right on. What we have to do is we have to look back. That's a common way to address something, especially, we have requirements, we already have 150 words in the sentence. So we're going to say any such. And you have to look back. What is the sense of a referent of that any such? If you can't, clear after the reference to section 1746, it makes it a lot easier to understand. It doesn't. And I sort of condensed it in my brief just for that reason. Because, finally, you know, I just, I had this case, I was possibly over the discussion still into that. So, you know, I think at the end of the day here, you know, sort of, you know, I see how it can be. I'm going to be for sure. I mean, even if... Well, they try. Things they do, they do, they do, are the same for many. It is after we've only called the standard technique, especially to reconstruction text, structure, legislative history of the class, grammar, everything. Then, if the court feels it's left with essentially guesswork, then the name must apply is the court must, you know, just very recently, in the subordinate case. That was the whole thing in that case, and the referent being court of the monity. So, I think at the end of the day, that backstop is really something that the court can't go about. If people would have done it, they can't get around. But, in any event, I do think the statute, which we plan to assess, as well, we even do here, the only sensible way into a voicer plusich is the adventuring, because other logic we have here, is exactly what unfolded. It doesn't really matter most people in these immigration forms. There's no need for me, there's no need for me. The statement and presented. This kind of 100s of forms, who knows, how many immigration forms there are, the statute implicates all of that. So, the monarchy here is a defendant basis statement. I'm from such on the citizen, and such and such, I'm applying for asylum, because I'm presokined. No, listen to asylum, listen to me. That's right, the session applies to all forms. And so, what happens is, the government is really, that the front air, the obviously applicable language, in most cases, which is binding of unbiased immigration form, is not an interpretation of this. Because, it was 95% cases where the person making the statement is also the person handing the form, they just tried to understand the vitality. That really stale to requirement out of the statute. And that's the last thing that came to mind. Why would you think the government wouldn't want to do that? Why would the government Congress take out the others from the bottom? Well, I think what Congress did was, it said, both big gave the gave the government the keys to bring any thrown in violence, and impose any oath on the law. We could have it both every time. It doesn't matter. But what Congress recognized was, there's a range of statements that are being in the Russian documents. Or, we can notice, this is not the only rule, the cost of marriage, and this is the limited-below to the apartment. That's the single-optimal's important documents. They say, well, the ones that are critical to enforcement, and you know what, government, you make the choice. You make the decision

. So, I think at the end of the day, that backstop is really something that the court can't go about. If people would have done it, they can't get around. But, in any event, I do think the statute, which we plan to assess, as well, we even do here, the only sensible way into a voicer plusich is the adventuring, because other logic we have here, is exactly what unfolded. It doesn't really matter most people in these immigration forms. There's no need for me, there's no need for me. The statement and presented. This kind of 100s of forms, who knows, how many immigration forms there are, the statute implicates all of that. So, the monarchy here is a defendant basis statement. I'm from such on the citizen, and such and such, I'm applying for asylum, because I'm presokined. No, listen to asylum, listen to me. That's right, the session applies to all forms. And so, what happens is, the government is really, that the front air, the obviously applicable language, in most cases, which is binding of unbiased immigration form, is not an interpretation of this. Because, it was 95% cases where the person making the statement is also the person handing the form, they just tried to understand the vitality. That really stale to requirement out of the statute. And that's the last thing that came to mind. Why would you think the government wouldn't want to do that? Why would the government Congress take out the others from the bottom? Well, I think what Congress did was, it said, both big gave the gave the government the keys to bring any thrown in violence, and impose any oath on the law. We could have it both every time. It doesn't matter. But what Congress recognized was, there's a range of statements that are being in the Russian documents. Or, we can notice, this is not the only rule, the cost of marriage, and this is the limited-below to the apartment. That's the single-optimal's important documents. They say, well, the ones that are critical to enforcement, and you know what, government, you make the choice. You make the decision. So, that's right, the statute. So, it makes sense that there will be a real requirement. Now, from the presentation, how does it actually be a maker and a presenter at the same time? Absolutely. How does that help us understand the statute? That because of this and that the two distinct provisions. Because basically what that would be under the government's reading, whether the dichotomy would be both a positive one and not the other. You know, if that is what really happened here, something that you know that as was originally charged here, what really happened something that you didn't see, but it wasn't happened to the government. Then that oath requirement becomes, it gets tossed out of the garbage, because if the government can say, ah, forget that, I'm going to charge this as a present with document and get out of that with the requirement. That's what they're charging. That's what they get here. So, if that informs the reading of the statute, which is, we should be suspicious of that. We should be suspicious of the Congress, Congress would write a statute starting off saying, the state and the state and the state and the under of the material, that is not making it, and it's requiring not to apply in the five million Congressional prosecutions. But this is in the sense. So, that's what's the positive thing I'm talking about. But what we sense to oppose the other requirement is that somebody will make a false statement because the person is making it, which it's a word to write down. But somebody presenting it, you can present it over the mail, right? So, you wouldn't be making, you wouldn't be presenting it, how it will take in the notes. Well, I think that the government is smart enough as to why, out of that box of the speak of, you know, making all this a passage, is that now we're worried about, actually, there were about, the makers who are, who are, who are, who can be, isn't, who may be not, and the presenters, that are, they are the ones that the government says, well, there should be, you know, there should be, in this line, really, for them, the broadest line, really, because they're the ones who are gaining the handling of the document, but that's not going to fit the facts in the situation, like you're understanding the government, they're the girlfriend, maybe you're never, actually, because that's not going to be this, necessarily, this is possible. One reason, Gordon, is that there is no reason, the government says that, you know, there's a good reason, for just having the rules for makers, not for present-on-the-presentation costs. And that reason is, because you only have these, makers who don't really, don't really know, they're distant, they only know that their statements are going to be used in an immigration document, and some of these, potentially, some people are there, we don't know, we want to impose a reliability, a reliability department. That's just not the case, because when you look at the statute, it was absolutely like this, this is under the floor, a state-of-the-art case, from a few times ago, this is on court, and it's on court, both the maker of the state and the representative of the state have two requirements, they must know the state-of-the-art, and you know, that it's going to be used in an immigration document. So there's no, there's a whole engine, driving the government's, you know, obligated for, you know, opposing the bill with open-air home agent clause, and not the present-on-the-present clause, is a issue, I mean, what really is going on here, is that there was a long charge in this case. Thank you, Mr. President. I think the problem with that already, is that the law is talking, it has to be on the right to start it by the standards

. So, that's right, the statute. So, it makes sense that there will be a real requirement. Now, from the presentation, how does it actually be a maker and a presenter at the same time? Absolutely. How does that help us understand the statute? That because of this and that the two distinct provisions. Because basically what that would be under the government's reading, whether the dichotomy would be both a positive one and not the other. You know, if that is what really happened here, something that you know that as was originally charged here, what really happened something that you didn't see, but it wasn't happened to the government. Then that oath requirement becomes, it gets tossed out of the garbage, because if the government can say, ah, forget that, I'm going to charge this as a present with document and get out of that with the requirement. That's what they're charging. That's what they get here. So, if that informs the reading of the statute, which is, we should be suspicious of that. We should be suspicious of the Congress, Congress would write a statute starting off saying, the state and the state and the state and the under of the material, that is not making it, and it's requiring not to apply in the five million Congressional prosecutions. But this is in the sense. So, that's what's the positive thing I'm talking about. But what we sense to oppose the other requirement is that somebody will make a false statement because the person is making it, which it's a word to write down. But somebody presenting it, you can present it over the mail, right? So, you wouldn't be making, you wouldn't be presenting it, how it will take in the notes. Well, I think that the government is smart enough as to why, out of that box of the speak of, you know, making all this a passage, is that now we're worried about, actually, there were about, the makers who are, who are, who are, who can be, isn't, who may be not, and the presenters, that are, they are the ones that the government says, well, there should be, you know, there should be, in this line, really, for them, the broadest line, really, because they're the ones who are gaining the handling of the document, but that's not going to fit the facts in the situation, like you're understanding the government, they're the girlfriend, maybe you're never, actually, because that's not going to be this, necessarily, this is possible. One reason, Gordon, is that there is no reason, the government says that, you know, there's a good reason, for just having the rules for makers, not for present-on-the-presentation costs. And that reason is, because you only have these, makers who don't really, don't really know, they're distant, they only know that their statements are going to be used in an immigration document, and some of these, potentially, some people are there, we don't know, we want to impose a reliability, a reliability department. That's just not the case, because when you look at the statute, it was absolutely like this, this is under the floor, a state-of-the-art case, from a few times ago, this is on court, and it's on court, both the maker of the state and the representative of the state have two requirements, they must know the state-of-the-art, and you know, that it's going to be used in an immigration document. So there's no, there's a whole engine, driving the government's, you know, obligated for, you know, opposing the bill with open-air home agent clause, and not the present-on-the-present clause, is a issue, I mean, what really is going on here, is that there was a long charge in this case. Thank you, Mr. President. I think the problem with that already, is that the law is talking, it has to be on the right to start it by the standards. Thank you. I think the bottom of the battle arm in the defense department is when the statutory history of the statute has started from 1948. Now, the original line of the open-air law is in full states, in the other words, there's no language about present-on-the-present clause, there's no material line, there's a bad point. The 1950s, it was amended, and the present-on-the-present clause was... You said that's clear. Go ahead. It's, it's, it's amended, 1952 at the same time, a material line, the material line, which is added. But perhaps the most important... Excuse me, why are you on 1952? But you said that it's clear that when the present-on-the-present clause was added in 1952, the law is such referring to the material line. The last thing I'm going to do, again, with the statute... That's right, I mean hard, you mean? Absolutely, as I've explained it, we have the line of the same time also, as I think something to that one. Perhaps the most important entity is the one in 1996, where the court then hands the language, or which fails to contain any useful basis in law, or in fact, to the present-on-the-present clause. Castlewood and his briefing allows that, that section of the book that was perceived in that section, doesn't require life. So what we're meant to book, then is that for food ten years, from 1952 to 1996, and those required ten clause that encarons, and they're not being aware of that, decided to end this section that does not require life. And I would suggest that the court attack leads to a certain zone, because now what you want, what the fact-finder's left with, or the name of the court is left with, is trying to determine the factual question, is it a false statement, or is the same as the fact that you're taking a useful basis in law, in fact, does a false statement, according to the defendant requires a note, if the statement was the fact that you're taking a useful basis in law, in fact, it doesn't. And I would suggest that the court attack is one of these absurd results that statutory interpretation cannot be listed. Are we a little more careful, charging of legal and civil-sacred results? No, no, I might tell the past people, we're more careful almost everything I do in life, but then this is a certain one example where- I know it is a wrong absurd results, right? But, of course, she's- Yes, I know, I know

. Thank you. I think the bottom of the battle arm in the defense department is when the statutory history of the statute has started from 1948. Now, the original line of the open-air law is in full states, in the other words, there's no language about present-on-the-present clause, there's no material line, there's a bad point. The 1950s, it was amended, and the present-on-the-present clause was... You said that's clear. Go ahead. It's, it's, it's amended, 1952 at the same time, a material line, the material line, which is added. But perhaps the most important... Excuse me, why are you on 1952? But you said that it's clear that when the present-on-the-present clause was added in 1952, the law is such referring to the material line. The last thing I'm going to do, again, with the statute... That's right, I mean hard, you mean? Absolutely, as I've explained it, we have the line of the same time also, as I think something to that one. Perhaps the most important entity is the one in 1996, where the court then hands the language, or which fails to contain any useful basis in law, or in fact, to the present-on-the-present clause. Castlewood and his briefing allows that, that section of the book that was perceived in that section, doesn't require life. So what we're meant to book, then is that for food ten years, from 1952 to 1996, and those required ten clause that encarons, and they're not being aware of that, decided to end this section that does not require life. And I would suggest that the court attack leads to a certain zone, because now what you want, what the fact-finder's left with, or the name of the court is left with, is trying to determine the factual question, is it a false statement, or is the same as the fact that you're taking a useful basis in law, in fact, does a false statement, according to the defendant requires a note, if the statement was the fact that you're taking a useful basis in law, in fact, it doesn't. And I would suggest that the court attack is one of these absurd results that statutory interpretation cannot be listed. Are we a little more careful, charging of legal and civil-sacred results? No, no, I might tell the past people, we're more careful almost everything I do in life, but then this is a certain one example where- I know it is a wrong absurd results, right? But, of course, she's- Yes, I know, I know. But I don't think that turns this case, I think we'll be able to assess the story line, which the history, I think the statutory history, are important in this case, and the purpose of the statute. It's a really patchwork piece of legislation, whatever you say you have to show it to the history. Of course, the problem is that a statute that's currently in the nature is supposed to inform, readily, someone who reads a, what comment is criminal? And that's- we really do process this, and we're supposed to be able to read it, and then I- I would say that if I were to say, I would be able to document your crime. But the statute is simple. My last line, my statement yesterday, I guess, will be on. Basically, your investigation says, you're not the commit. You're not the defendant full statements in a Christian document. That's what it says. Now, does the defendant think an ungrateful amount of the amount of the fact that- he's a decent host? Don't present full statements in a Christian document, because you're a citizen of the government. That's what you're in this case. Thank you. Thank you. We'll take the matter under investigation.

We'll start with the United States versus Asheville. Okay. Good morning. Good morning. Good morning. The mayor police of court, my name is Anthony Zorke. I represent the government in this case and the government that's being held. There's two major positions that have been held. I was asked to resort about two minutes for a bottle of space. Okay. Question raised in this appeal is whether a material false statement made an immigration document and presented immigration authority must be made under oath or penalty of perjury to be a violation of Section 1546A. The government submits that it does not that the presentation alone of the immigration paperwork knowing that it contains material false statements is sufficient. We have to look at the statute. Absolutely. We have to ask that you have. The defendant and the defendant send the district court to disagree the government's position. The government's position is supported by the text and the structure and the purpose of the statute. We just not said clear. We just not decided to give it clear. But as this court has said almost every statute has some ambiguity in it. Well, kind of it doesn't get out of the screen when you are in the statute, but I'm not sure that I would say every side. That's a strong statement. Go ahead. Especially for the government to make. We're not asking for the third circuit. No, for me. The government's position is also supported by the case and the second circuit and by the statutory history. I don't see just the misguided. The first thing I asked the court to look at is the purpose. It was a, it was a, it's not a sign looked at up. It's not a sign opinion. It's a court of courier. I just second circuit. I want to know. You are a legal lawyer. You can't approve of some statute. The language of the statute is critiqued. Absolutely. Okay. And then you have a section there. And you say such refers only to half of what precedes it. Under statute to a construction, how can you say a such can pick out what it refers to? Well, you're right. I think what you have to do when you look at that language. There are two uses of the right quality, the very such as in that section. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. And then you have to make a statement. To be consistent in this statute. To be consistent in this statute. This is where I had to tell you. I had to tell you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. I kept my cake to you. It's a perfect example of Congress and the birthday of Nathaniel and Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. Richard Marshall. What I may ask him is how do you look at this on the first or second reading and understand that if I decide to start to get an intern it over to a school, I may be subject to theory as a prison, if that state ends up in jail. I just want to talk a bit about the document that was contained in the glass. I think that I would like to say- Everybody agrees. I think we agree. I think we agree. I think we agree. If not, it isn't true. Yes, Your Honor. But I don't question Dutch Frances. asks, does that make a difference? I'm sorry. It didn't, too. It did not intend to stay in a full course, etc. Well, I think you'll look at what we're taking and what's in the facts of this case, and you'll just look at the statute and then go back to the judge's initial heart and the initial statement, how do you know what should do you get wrong? I think most people are looking at the facts of this case, most people are going, if they lie, and the government that gives us a government that government who lies on, they get something back from it, that's wrong. I can make a misread. You know, I don't know if it's me. But what's the true about it? Then he said that, that he attended the program for excellent number of hours and... He intended to, he intended to, but he realized that they were showing video movies at this program and it really wasn't the program. It really changed his seat. Well, let's say he has a misrepresentation because he wasn't going to require any number of hours per day. Is there something Jay could tell me that if that statement was wrong, and he submitted to the schooling that it presented for 10 years? You're on our first wall. The one that's as offended as we've got for a certain amount of hours, he's going to get all, what would he be doing? But he was black, he wasn't, what would he be doing? Well, he said he was doing other things, what would he be doing? I'm trying to get a picture of him again. There he is. I'm telling you, the statute, and it's kind of, when I see it, it fits. The only problem is understanding what this says on the first or second reading, and I just think it's impossible. Well, I'm going to go try to make this right now, and I'm afraid to make this right now. I don't really look for it to people in this room that would know the same. God, I don't want to disagree with you that when the first reading a statute it takes some time to go back over and read it. But I think when you look at the purpose of the statute, when you look at the statutory history in this case, then we look at the language of it, and I didn't complete that last section of it, but when you look at the, such as the, or as the fourth statement, you go back and it should be in the same world and the fourth statement, and it follows it, which in this case is material of course. So I see the, as to the East of the language, I suggest that the defense's argument is formed. As to the purpose of the statute, when you look at the entire statute, all four paragraphs, you find that God was cruel and was intended to prohibit all four-general action-going immigration documents, they prohibit the four-gen caliphate and both were falsely making others and using possessing a ten-general sect of accepting, receiving the immigration documents and on the fourth caliphate, falsely making the first statement, and on the bottom, and then you get to this part where you say, well, they must have not had in their concentration as someone who presented a document of wise and at false statements that they're going to lie on, but that would be a lie. He was originally charged with making a statement under mouth, wasn't it? And then why was that changed? You're not allowed to interpret, or should the trial have looked at, otherwise that would have been blinded. It's part of the argument. Confused by the statute. Confused by the statute? Confused that was just, I don't know. I was just a little sad. I don't know what I was saying. They had to be invited to conform with your review, and I decided to leave the statute. Well, I'll tell a bit more closely, I sure. But if you wanted to get this guy for making a small statement under statement under your own, for his false, you could, because he did. You just picked the wrong document. There was, well, the big event would go back to the original documentation. I must surely still be statute of that, but I think you probably would have been close. So this was the most applicable one, and I'm sure you've been wondering how to prevent this one, because as I quoted here earlier, it's not something that makes the false statement, but at the time he makes the statement, how can you show that he intended the default to go? In this case, we had him not going to classes of all, not paying tuition, but we're going to have a job. How do you do the classes, sir? Not for the one equal, but for January 22, 2010, until June 20, 2010, came in with 10 more requests. And you can kick him out of the country anyway, right? That's the right thing, right? Yes, that's true. I'm going to ask the court to look at the statute or the history of case that perhaps this is the most important factor since the court has not really, I would have been able to indicate that they're going with the classes of all of the statute. But then take what we asked in the court. I apologize. I mean, we know that's our job to press you. Could she sit with our job? Yes, the help card is in the current presenter. It will be the mayor of a document that is under a false form. He can be a presenter of a document that contains materially false statements. He presented it to the official open school back in the summer. He's like, I don't know. Official at that one. The quasi-government. Well, she's representing the government in this program, the Seifers program. Just that in government. No, she's not crying. And she's acting in a place that government that put in. Is she implicit that in documentation she gets into a computer system? Yeah, I don't have a basis for that. And what is there is there a basis for confirming that? She is, in fact, the government of the issue. She's not a government official, though. Well, she acts instead of the government. I mean, she, there are no, she, she to plot, takes the information he gives. She implicit into a computer and that goes to New York. Because she has the same. I see in the paper work. Yes, sir. And his presenting a document that contains a file statement is the act that's adjacent to the criminal penalty. Yes, sir. How often does the government prosecute people for unsworn statements? I never think I've ever seen it. Not been in 34 years. Well, I've seen it. I only have 18 years long, and I can't answer that question. You're so kind of uncertain. Question, does it hurt? Yeah, when you do your tax return, you get your fake. It goes to somebody who nets somebody files a foreign with the government, but there's a provision at the, above your signature that says, sir, the here is not true or in trouble. Well, at least he gives her a form. And she also swears under a number of penalty encouraging the virtue of the correctness. But there was nothing in the document that he submitted that would alert him that if anything in the document itself, it's false. He would be subject to criminal penalties. He said that he's certified that the state is a true or correct, he's certified according to the, to the, to the, there's a certification in the document that he signed. Yes it was. OK. Just saying that I certified the state is a true or correct. OK, that's different from an oath. Yes, it's different. Isn't the statute at least ambiguous? I look at what we're, we're going through. I look at the papers that have been written. And if it was ambiguous, are we required to pardon more than anything? You're on the, what the court has said in the past is that the third circuit said after the one accounts. Yes. And he said, if, if after considering the tax structure of history of the statute to remain a group and a community, or on the circuit of the statute, then, then the rule of any apply. And she's, through his own say, doesn't apply, only there's a mere, see, this is what I said, or the mere suggestion around the community, because most statutes are ambiguous to some degree. So, and I just, well said, she didn't say that. It's about it. And I expect that in the, in my very often, but I expect that in front of the court oftentimes, the argument is, oh, the statute, what it means. And what doesn't mean. That's what I mean. That's what I'm just, that's what I am. That's what you're saying. OK. OK. What are you on the bottle? Good morning, ladies and gentlemen. That's why Senator Lucas Henders here represents Derracheol today. Mr. Schmeitzer, he obviously applied. It's obviously, it's close. Why doesn't the government have the right to say, you know, you want something from us, you want a visa, who gave us a first document. We're not going to accept that. We're not going to let you get away with that. Why isn't the government entitled to that? Well, because there's no doubt that the fourth paragraph of 1546 focuses on those. It puts out the very old requirement. The issue is, does it, does it, is it limited somehow to the makers, the making laws of the pathetic law? And I'm submitting Derrach to background critical facts here, which really go to your owners' question and show that there's no problem with the defense reading the statute, the appropriate reading the statute. One is that, again, the oath requirement is the very first statement mentioned in session four. We get the paragraph four. We get the, it's okay, this is about the statement, the false statement is the number of. Those are the report statements, those are the most culpable statements. But he knew it wasn't correct. Well, we were on the respect to the judgment panel and the court had actually been in the wrong table. And the court had been on the first count again, convicted on the second count, and they had found you were at the student level. But in the scheme of four things, for the last minute here, it's been total control of what is the statement. So, it's been total control of the whole criminal section? No, you're right. I would say you're more precise. It makes the immigration forms. It provides, it requires whatever indienes which ever states it deems the most critical to immigration enforcement, that it was important, that it was material, why am I, it imposes the law. So, there's other issues before, if they want to. The government can change the form. So, you know, with those two, that... I think this is after the second circuit opinion. What does that mean? Which language one against the government? Well, the scientific opinion actually held that the American economy doesn't apply with respect to the presentation. However, in fact, this is never been cited. It's sort of out there in 30 years. Well, this doesn't come up that often. That's what I... I'm not sure, I think it's because the government... This isn't a big problem. The government wants the forms. The government specifies which things are to be sworn which are... The government can charge. They could charge the one 15th, the one 15th of I-19. Excuse me. What is that? Is that out of the statute of limitations? Or is it still? I had to work out the date, but no, the statute's to conform to the relevance, you know, how it's looking in charging. Maybe they should charge earlier, who knows? They could have charged on to the digital culture, meaning they could have charged... So they could have charged on to the rationality presenting the secure state that was under arrest. So, once you understand this, you can see that there isn't a free car. It can never afford. And the government can prove that both anytime they want, that both the government and the doctors, anytime they want. The only thing the only sensible in the statute is that sworn statements, important statements, that's going to need to come from liability, once sworn statements are not relevant. And Jeff Sauer, when he was talking about it, he would only present to you a document that could date a falsehood. And that's the government's interpretation. Well, it's unreasonable about imposing penalties and somebody that, consistent with the reason that he's trying to preserve makes a false statement to be official. Well, it is, like, a reasonable for the government to write an over-carbon signature in the right unreasonable for the government to say that the oath required doesn't apply to the present. The doctor, that no one thinks false. And what a problem with that is, it's too false. It needs to tell the attorney that it was all too late. And it needs to be just a false description. Stop there and tell us why it's totally all the truth. Because it's on the government's reading. Okay, well, there's an un-sourced statement. If the person who makes that statement submits it to the government, that is a non-climbed, but it's even the government that admits that there's no both requirement for someone who makes a statement. But we always do defend it instead. It's said to go into this position, as I understand it, to be the government, it says, we're representing the document that contains a false statement with respect to a material fact that doesn't require the agreement. And that's what it says as a as-rock English case, that they should be. That's correct or not, I don't know. Just letting it particularly happen. I think it does address your point. The issue is too high, we see it get to that. The government, we'll talk about that in a second, but the government says... Is that for the judges? The government says that this bill for you are applying to seek is made by the person and submitting it in a form. But it doesn't apply with the person presently in a presenter, you know, the person who presents the form. It doesn't apply that contestation, or if you're pardoned for presenting it, so let that be announced. What does that make any sense by the way? It doesn't make any sense, because it makes sense. So I mean, why would Congress have done that? I would say, it doesn't make sense to draw the line of criminal life that will lead to some makers and quote-makers and quote-presenters. But Congress did it. Well, the statute that emits a lot. The statute of rules does that, and it makes a lot. Well, no, it does. But the question is, what does the oath of requirement apply to the Department of Health or does it apply to one? So I would suggest to your honest that the critical point here is that it has some piece of statement and gives it to the government. Under the government's view, that unswore statement is what's working out. Unswore statement under the government's view, no crime. But if that same person makes the same oneswore statement, it takes it to a equivalent of attack, curb-per-region service, or has someone presented all the sudden has a crime. And that makes no sense. It makes no sense. Why criminal liability would turn on? Who he is to go? Who he is to the government? The document to the government. Now, just one case, with respect to your point, now, presentation, I think it's an excellent one. I think that the Friday, which I would be, was held in the brief. There's an alternative basis here, the firm, which is the differential of, isn't just the assumption of, it's efficient since it's trash off, is not the percent of all. The DSO, the state, is a presently in the sense of currently in the document. But I had had some questions about that, and that may represent the governor. So that may be subject to the statute. And I won't think it will be. I have a free presentation under the statute, must be intended to the government, it's an integration document. Now, this testimony was perfectly clear from the government's what this is the experts in this program brought in from a place they said, a student cannot access that database. The submission to the government happens by the school official, to school official, put it into the computer database, and that's what happens. So I do believe, if the court might climb that, that sort of thing, that's a really, really, really, this issue. Now, I would like to show, you're on this cover, you can't see. But this is one more cup of the statute. Full cover, circles, arrows, everything has a spectrum. And you're on this, maybe that's something similar. When you go back to the statute, statutory construction, you've got a such. And what is the such referred to? To me, I find it difficult to conceive how you can pick and choose any such, when you talk about, present any such application. The letter it normally makes under oath, any full statement with respect to the material fact in any application. Or knowing you present any such application. It seems to me that any such application has to include making it under oath and being material. And how do you just say, I'll refer to that thing and not to that thing. I think you're absolutely right on. What we have to do is we have to look back. That's a common way to address something, especially, we have requirements, we already have 150 words in the sentence. So we're going to say any such. And you have to look back. What is the sense of a referent of that any such? If you can't, clear after the reference to section 1746, it makes it a lot easier to understand. It doesn't. And I sort of condensed it in my brief just for that reason. Because, finally, you know, I just, I had this case, I was possibly over the discussion still into that. So, you know, I think at the end of the day here, you know, sort of, you know, I see how it can be. I'm going to be for sure. I mean, even if... Well, they try. Things they do, they do, they do, are the same for many. It is after we've only called the standard technique, especially to reconstruction text, structure, legislative history of the class, grammar, everything. Then, if the court feels it's left with essentially guesswork, then the name must apply is the court must, you know, just very recently, in the subordinate case. That was the whole thing in that case, and the referent being court of the monity. So, I think at the end of the day, that backstop is really something that the court can't go about. If people would have done it, they can't get around. But, in any event, I do think the statute, which we plan to assess, as well, we even do here, the only sensible way into a voicer plusich is the adventuring, because other logic we have here, is exactly what unfolded. It doesn't really matter most people in these immigration forms. There's no need for me, there's no need for me. The statement and presented. This kind of 100s of forms, who knows, how many immigration forms there are, the statute implicates all of that. So, the monarchy here is a defendant basis statement. I'm from such on the citizen, and such and such, I'm applying for asylum, because I'm presokined. No, listen to asylum, listen to me. That's right, the session applies to all forms. And so, what happens is, the government is really, that the front air, the obviously applicable language, in most cases, which is binding of unbiased immigration form, is not an interpretation of this. Because, it was 95% cases where the person making the statement is also the person handing the form, they just tried to understand the vitality. That really stale to requirement out of the statute. And that's the last thing that came to mind. Why would you think the government wouldn't want to do that? Why would the government Congress take out the others from the bottom? Well, I think what Congress did was, it said, both big gave the gave the government the keys to bring any thrown in violence, and impose any oath on the law. We could have it both every time. It doesn't matter. But what Congress recognized was, there's a range of statements that are being in the Russian documents. Or, we can notice, this is not the only rule, the cost of marriage, and this is the limited-below to the apartment. That's the single-optimal's important documents. They say, well, the ones that are critical to enforcement, and you know what, government, you make the choice. You make the decision. So, that's right, the statute. So, it makes sense that there will be a real requirement. Now, from the presentation, how does it actually be a maker and a presenter at the same time? Absolutely. How does that help us understand the statute? That because of this and that the two distinct provisions. Because basically what that would be under the government's reading, whether the dichotomy would be both a positive one and not the other. You know, if that is what really happened here, something that you know that as was originally charged here, what really happened something that you didn't see, but it wasn't happened to the government. Then that oath requirement becomes, it gets tossed out of the garbage, because if the government can say, ah, forget that, I'm going to charge this as a present with document and get out of that with the requirement. That's what they're charging. That's what they get here. So, if that informs the reading of the statute, which is, we should be suspicious of that. We should be suspicious of the Congress, Congress would write a statute starting off saying, the state and the state and the state and the under of the material, that is not making it, and it's requiring not to apply in the five million Congressional prosecutions. But this is in the sense. So, that's what's the positive thing I'm talking about. But what we sense to oppose the other requirement is that somebody will make a false statement because the person is making it, which it's a word to write down. But somebody presenting it, you can present it over the mail, right? So, you wouldn't be making, you wouldn't be presenting it, how it will take in the notes. Well, I think that the government is smart enough as to why, out of that box of the speak of, you know, making all this a passage, is that now we're worried about, actually, there were about, the makers who are, who are, who are, who can be, isn't, who may be not, and the presenters, that are, they are the ones that the government says, well, there should be, you know, there should be, in this line, really, for them, the broadest line, really, because they're the ones who are gaining the handling of the document, but that's not going to fit the facts in the situation, like you're understanding the government, they're the girlfriend, maybe you're never, actually, because that's not going to be this, necessarily, this is possible. One reason, Gordon, is that there is no reason, the government says that, you know, there's a good reason, for just having the rules for makers, not for present-on-the-presentation costs. And that reason is, because you only have these, makers who don't really, don't really know, they're distant, they only know that their statements are going to be used in an immigration document, and some of these, potentially, some people are there, we don't know, we want to impose a reliability, a reliability department. That's just not the case, because when you look at the statute, it was absolutely like this, this is under the floor, a state-of-the-art case, from a few times ago, this is on court, and it's on court, both the maker of the state and the representative of the state have two requirements, they must know the state-of-the-art, and you know, that it's going to be used in an immigration document. So there's no, there's a whole engine, driving the government's, you know, obligated for, you know, opposing the bill with open-air home agent clause, and not the present-on-the-present clause, is a issue, I mean, what really is going on here, is that there was a long charge in this case. Thank you, Mr. President. I think the problem with that already, is that the law is talking, it has to be on the right to start it by the standards. Thank you. I think the bottom of the battle arm in the defense department is when the statutory history of the statute has started from 1948. Now, the original line of the open-air law is in full states, in the other words, there's no language about present-on-the-present clause, there's no material line, there's a bad point. The 1950s, it was amended, and the present-on-the-present clause was... You said that's clear. Go ahead. It's, it's, it's amended, 1952 at the same time, a material line, the material line, which is added. But perhaps the most important... Excuse me, why are you on 1952? But you said that it's clear that when the present-on-the-present clause was added in 1952, the law is such referring to the material line. The last thing I'm going to do, again, with the statute... That's right, I mean hard, you mean? Absolutely, as I've explained it, we have the line of the same time also, as I think something to that one. Perhaps the most important entity is the one in 1996, where the court then hands the language, or which fails to contain any useful basis in law, or in fact, to the present-on-the-present clause. Castlewood and his briefing allows that, that section of the book that was perceived in that section, doesn't require life. So what we're meant to book, then is that for food ten years, from 1952 to 1996, and those required ten clause that encarons, and they're not being aware of that, decided to end this section that does not require life. And I would suggest that the court attack leads to a certain zone, because now what you want, what the fact-finder's left with, or the name of the court is left with, is trying to determine the factual question, is it a false statement, or is the same as the fact that you're taking a useful basis in law, in fact, does a false statement, according to the defendant requires a note, if the statement was the fact that you're taking a useful basis in law, in fact, it doesn't. And I would suggest that the court attack is one of these absurd results that statutory interpretation cannot be listed. Are we a little more careful, charging of legal and civil-sacred results? No, no, I might tell the past people, we're more careful almost everything I do in life, but then this is a certain one example where- I know it is a wrong absurd results, right? But, of course, she's- Yes, I know, I know. But I don't think that turns this case, I think we'll be able to assess the story line, which the history, I think the statutory history, are important in this case, and the purpose of the statute. It's a really patchwork piece of legislation, whatever you say you have to show it to the history. Of course, the problem is that a statute that's currently in the nature is supposed to inform, readily, someone who reads a, what comment is criminal? And that's- we really do process this, and we're supposed to be able to read it, and then I- I would say that if I were to say, I would be able to document your crime. But the statute is simple. My last line, my statement yesterday, I guess, will be on. Basically, your investigation says, you're not the commit. You're not the defendant full statements in a Christian document. That's what it says. Now, does the defendant think an ungrateful amount of the amount of the fact that- he's a decent host? Don't present full statements in a Christian document, because you're a citizen of the government. That's what you're in this case. Thank you. Thank you. We'll take the matter under investigation