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Try CasePortal for FreePer curiam, the Fifth Circuit finds the district court properly convicted defendant for filing false liens against a federal judge in retaliation for his life sentence for drug trafficking. The clerk’s office received a document titled “Claim of Lien” via certified mail, which listed the judge as the debtor and defendant as the requestor. The “voluntary agreement” didn’t have the judge’s signature and stated that the lien arose from the judge’s “unlawful acts committed against the liberty interest of [defendant].” Defendant sought a total of $50 million for the alleged violations and attempted to file a notice of foreclosure on property owned by the judge. Mention of the warranty deed at trial and not in the indictment is not a constructive amendment to the element of mail fraud and did not allow conviction on a materially different theory or set of facts. Nothing suggested that a court issued the lien or a later “notice of default,” or that it arose from a judgment. Affirmed.