that occurred outside of the conspiracy dates charged in the indictment (as opposed to the statute of limitations dates), that did not constitute a fatal variance” (citations omitted)). Decisions from other circuits are directly on point. The clear majority of them have concluded that unless the date of an offense constitutes a critical part of the offense, “a variance in the dates charged in the indictment and those proved at trial will generally be harmless if the government proves that the offense was committed on any day before the indictment and within the statute of limitations.” United States v. Scheuneman, 712 F.3d 372, 379 (7th Cir.2013) (internal citations, quotation marks, and alterations omitted); see also United States v. Wells, 646 F.3d 1097, 1103-04 (8th Cir.2011) (<HOLDING>); United States v. Daggs, 448 FedAppx. 504, 508
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 the date of the federal indictment not the date of the state arrest was the triggering date for the speedytrial act 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 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 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