An immaterial difference of recollections is not perjury

Byron York:

Recent news reports and commentary have suggested that top White House adviser Karl Rove might be under investigation for perjury in the Plamegate affair. But sources familiar with the probe say the most frequently cited evidence for such speculation — an apparent inconsistency between Rove's and Time magazine reporter Matthew Cooper's accounts of a July 11, 2003, telephone conversation — falls far short of being the basis for any prosecution, much less a perjury charge.
Witnesses to the same event can have inconsistent memories of the event without either of them lying. It happens all the time in legal proceedings whether it involves witnesses to a traffic accident or peoples different recollections about a business transaction. Since the contemporary documents, i.e. an email from Rove describing the conversation, supports Rove's recollection, the case is even weaker. York interviews several experts who come to the same conclusion.

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