The following excerpt is from U.S. v. Lieberman, 637 F.2d 95 (2nd Cir. 1980):
United States v. Lang, 589 F.2d 92, 97 (2d Cir. 1978). Gaines's statements clearly tended to subject him to criminal liability, and there is no basis for supposing that he did not believe them to be true.
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