The charges themselves—attempting to procure naturalization contrary to law or when not entitled thereto—are not themselves particularly complex. See United States v. Munyenyezi, 781 F.3d 532, 536-37 (1st Cir. 2015) (discussing elements of these offenses); Munyenyezi v. United States, 989 F.3d 161, 166-67 (1st Cir. 2021) (discussing materiality element of subsection (a) in light of Supreme Court's holding in Maslenjak v. United States, 582 U.S. 335, 137 S.Ct. 1918, 198 L.Ed.2d 460 (2017)). With respect to Count One, the indictment identifies the specific form containing the alleged false and fraudulent information—Gasana's Application for Naturalization, Form N-400.

Indeed, the presence of this type of non-sensical redaction in 500 pages of claim files with dozens and dozens (if not hundreds) of redactions, brings to mind the statement about the ”thirteen stroke of a clock at midnight” that calls into question not only itself, but everything that has come before. See Munyenyezi v. United States, 989 F.3d 161, 1691-70 (1st Cir. 2021) (explaining that a jury may have viewed a certain lie in testimony “as the thirteenth stroke of Thomas Hardy's crazy clock: ‘It was not only received with utter incredulity as regarded itself, but threw a doubt on all assurances that had preceded it.' Thomas Hardy, Far from the Madding Crowd 209-10 (First Vintage Classics ed. 2015)”); In re United Merchants and Mfrs., Inc., 3 B.R. 286, 299 (S.D.N.Y. 1980) (“very like the thirteen stroke of a clock, which raises serious doubts as the reliability of the first twelve strokes”) (quotation omitted).

Id. Milosevic relies on Maslenjak and a handful of other cases to argue that the government has not established the materiality of his false statements because it has not shown that he was actually ineligible for the immigration benefits he received. See Def.’s Opp., ECF 86 at 19-21 (citing, inter alia,United States v. Maslenjak , 943 F.3d 782, 786 (6th Cir. 2019), Munyenyezi v. United States , 989 F.3d 161, 167 (1st Cir. 2021), and United States v. Malik , No. 15-9092-CM, 2019 WL 2054110, at *6 (D. Kan. May 9, 2019) ). But as the Maslenjak Court acknowledged (and, indeed, as Justice Gorsuch, in his concurring opinion, noted with disapproval), the question of actual ineligibility is an issue of causation in the context of naturalization proceedings, not of materiality.