Section 287 requires proof that a false claim was made against the government, a fact that section 1001 does not require, because not every false statement to government officials comprises a claim against the government for money or services. Similarly, section 1001 requires proof of a false statement, a fact that section 287 does not require, because a false claim against the government can be made without making a false statement — such as by endorsing and cashing a check to which one is not entitled, see, e.g., United States v. Branker, 395 F.2d 881, 889 (2d Cir.1968), cert. denied sub nom. Lacey v. United States, 393 U.S. 1029, 89 S.Ct. 639, 21 L.Ed.2d 573 (1969); Dimmick v. United States, 116 F. 825 (9th Cir.1902), cert. denied, 189 U.S. 509, 23 S.Ct. 850, 47 L.Ed. 923 (1903) (<HOLDING>); see also United States v. Lopez, 420 F.2d
holding that bill of review brought in wrong court constitutes collateral attack holding that bill of review is exclusive remedy on direct attack where court had jurisdictional power even if judgment void holding that bill of lading issued as to two containers was binding as to third container which was stolen and as to which no bill of lading issued provided that the bill of lading in evidence was the standard form bill of lading that carrier always used holding that demand upon a bill already paid or unauthorized demand upon unpaid bill constitutes a false claim even though bill itself contains no false statement holding that the meritorious defense requirement in a bill of review proceeding violates due process where the bill of review plaintiff has no notice of the proceeding in which the default judgment was rendered