DOJ-OGR-00003090.jpg

Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 156 of 239 denial ...”). A properly instructed jury could conclude after hearing all of the evidence at trial that the defendant intended the natural meaning of the words she used, not the allegedly truthful answer she suggests now, and therefore that she lied. In sum, the defendant’s post-hoc efforts to inject confusion into clear questioning are unavailing and should be rejected, and the jury should decide whether the defendant’s answers were false. 2. July 2016 Deposition Count Six charges the defendant with perjury arising from three colloquies at the second deposition. Following that line of questioning, the following colloquy occurred: 129 DOJ-OGR-00003090