What constitutes material evidence, fact, statement or information to a judge or magistrate under section 3C1.1 of the Criminal Code for obstructing justice?

U.S.S.G. 3C1.1 mandates a two-level increase in offense level "[i]f the defendant willfully obstructed or impeded, or attempted to obstruct or impede, the administration of justice during the investigation, prosecution, or sentencing of the instant offense." See Ancheta, 38 F.3d at 1118 (emphasis added). "[P]roviding materially false information to a judge or magistrate" is an example of conduct which implicates a 3C1.1 upward adjustment. See U.S.S.G. 3C1.1, application note 3(f). " 'Material' evidence, fact, statement, or information, as used in this section, means evidence, fact, statement, or information that, if believed, would tend to influence or affect the issue under determination." U.S.S.G. 3C1.1, application note 5; see also United States v. Magana-Guerrero, 80 F.3d 398, 400 (9th Cir.), cert. denied, --- U.S. ----, 117 S.Ct. 141, 136 L.Ed.2d 88 (1996).

In order to qualify for the upward adjustment under 3C1.1, a defendant must "consciously act with the purpose of obstructing justice." United States v. Lofton, 905 F.2d 1315, 1316-17 (9th Cir.), cert. denied, 498 U.S. 948, 111 S.Ct. 365, 112 L.Ed.2d 328 (1990). Here, appellant argues that the letter he submitted to the court was merely an attempt to elicit sympathy, and that the statements contained therein were not meant to have any material affect on his sentence. Appellant further contends that his full acknowledgment of his culpability prior to sentencing precludes the imposition of the obstruction of justice enhancement.