cites Scott K. Zesch, Annotation, When Does Statute of Limitations Begin to Run in Action under False Claims Act (31 U.S.C.A. §§ 3729-3733), 139 A.L.R. 645 § 4 (1997) and "the cases cited therein" for the proposition that the majority rule is that the limitation period begins to run when a claim is presented to the government agency for payment, rather than when the claim is paid. Most of the cases cited in § 4 of the annotation did not address the issue of whether the date of payment or of claim submission was the triggering date for the FCA statute of limitations, but merely held that the limitation period begins to run no earlier that the date on which the false claim is submitted. See, e.g., United States v. Ettrick Wood Prods., Inc., 774 F.Supp. 544, 552, 552 n. 12 (W.D.Wis.1988)
holding the correct date to use when determining the controlling statute is date upon which the claim arose 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 statute does not begin to run until at least a demand has been made upon the government but determining that the facts of that case made it unnecessary to choose between the date of demand and the date of actual payment as the triggering date for the running of the statute of limitations 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 interest does not begin to accrue until the date of judgment not the date of verdict