in subsequent proceedings .... Fed.R.Crim.P. 41(e). The government argues that Wilson’s motion is barred by the doctrine of laches, and the district court so held. “To assert the affirmative defense of laches, the party seeking immunity from suit must demonstrate that: (A) the opposing party inexcusably delayed the pursuit of its claim and (B) prejudice resulted from this delay.” Marolf, 173 F.3d at 1218. Here, Wilson brought his Rule 41(e) motion almost exactly twenty years after the property was seized. Although Wilson argues that he did not learn of the forfeiture until the Federal Bureau of Investigation (FBI) responded to his Freedom of Information Act (FOIA) request in 1999, we are satisfied that Wilson inexcusably delayed the pursuit of his claim in this case. See id. at 1218-19 (<HOLDING>). A person can be reasonably expected to become
holding that a fivemonth delay in filing a motion to disqualify did not bar the motion where there was a reasonable explanation for the delay holding that a district court has jurisdiction to consider  a rule 41e motion  filed after criminal proceedings had been completed holding that a year delay in filing a motion to disqualify did not bar the motion where there was no evidence that the motion was inspired by dilatory tactics holding that delaying the filing of a rule 41e motion for a year and a half after receiving actual knowledge of a forfeiture is evidence of unjustifiable delay holding that a district court has jurisdiction to entertain a rule 41e motion for the return of property before a criminal prosecution has begun believing such a motion to be in effect a civil action