that the date of a crime is not an element of the offense is consistent with our case law regarding the sufficiency of indictments containing factual disparities. In United States v. Hinton, 222 F.3d 664 (9th Cir.2000), for instance, we upheld an indictment which misstated the date of the offense by 18 days, and which misidentified the cities between which contraband was shipped in interstate commerce. In finding these errors to be insignificant, we held that “the test of the sufficiency of the indictment is not whether it could have been framed in a more satisfactory manner, but whether it conforms to minimal constitutional standards.” Id. at 672 (citing United States v. Rosi, 27 F.3d 409, 415 (9th Cir.1994)); see also United States v. Alviso, 152 F.3d 1195, 1197 (9th Cir.1998) (<HOLDING>). Our treatment of this issue in one recent
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 under a similar statute the government need only show that the defendant had the intent to carry on illegal activity and that the crime occurred in conjunction with interstate travel holding that the date of the offense was material to the defense where defendant could not have anticipated from the date specified in the indictment that the state would present evidence that the crime occurred nearly two months later holding that the government need not prove actual notice to the prisoner recognizing that the government need only prove that crime occurred reasonably near the date stated in the indictment