necessary to accommodate the prosecutorial interests that the sealing of an indictment legitimately furthers. Id. Only two courts have attempted to define more precisely a “reasonable time” for sealing purposes. United States v. Heckler, 428 F.Supp. 269, 272 (S.D.N.Y.1976); United States v. Sherwood, 38 F.R.D. 14 (D.Conn.1964), aff'd sub nom., United States v. Doyle, 348 F.2d 715 (2d Cir.), cert. denied, 382 U.S. 843, 86 S.Ct. 89, 15 L.Ed.2d 84 (1965). These two courts focused on the defendant’s availability to determine whether the length of the sealing period was reasonable. Heckler, 428 F.Supp. at 272 (“When the defendants are available the government may not seal an indictment for more than a reasonable time after the statute of limitation has expired.”); Sherwood, 38 F.R.D. at 20 (<HOLDING>). The government asserts that it sealed the
holding that the date of the federal indictment not the date of the state arrest was the triggering date for the speedytrial act holding that the 90 day period set out in rule 591 begins to run from the date of filing rather than the date set for hearing of the posttrial motion holding that the indictment should have been unsealed no more than 90 days from the return date the time period when the defendants were first available holding that where the date of the offense is not an element of the charge  a variance between the indictment date and the proof at trial is not fatal so long as the acts charged were committed within the statute of limitations period and prior to the return date of the indictment holding that an allegation as to the time of the offense is not an essential element of the offense charged in the indictment and within reasonable time limits proof of any date before the return of the indictment and within the statute of limitations is sufficient