Statements in police interviews framed as denials of knowledge or awareness may be capable of being lies evidencing consciousness of guilt where they contain implicit positive assertions that can be proved false by other evidence. Where multiple alleged lies are relied upon as circumstantial evidence, no individual lie constitutes an indispensable link in the chain of reasoning, and no direction is required that any individual lie be proved beyond reasonable doubt. The Davidson test for indispensable intermediate facts is a useful analytical tool but not a universal test.
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