The following excerpt is from U.S. v. Watson, 690 F.2d 15 (2nd Cir. 1979):
The majority seeks to escape all this by framing the issue in terms of a "tolling" of or an "exception" to the statute of limitations and quoting a statement in United States v. Marion, supra, 404 U.S. at 322, 92 S.Ct. at 464, that when the limitations period has passed, "there is an irrebuttable presumption that a defendant's right to a fair trial would be prejudiced". The analysis
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