begin any time when the act was performed again. For instance, if a false statement was allegedly made to a government official in 1996, and subsequently made again in 2006, the 10-year statute of limitations clock could start in 2006. If that person then takes the oath of naturalization in 2016, which incorporates all that was previously stated in the naturalization process, the 10 years could once again re-start from that point. The criminal denaturalization files reviewed for this report contained several instances in which the government waited far beyond the moment the offense was committed—sometimes over 20 years—using the date of naturalization as the date from which the statute of limitations began to run. In several other instances, the government has initiated cases just months before the 10-year deadline. In one case, the defendant moved for a “time lapse prejudice,” noting that he was: [P]rejudiced in his ability to defend himself in multiple ways as a result of this unjustified 9.5-year delay. First, at least two witnesses to his state of mind at the time he filled out the relevant paperwork—relevant to whether his actions were intentional—are not available to testify: one has passed away, and the other, it appears, has no specific memory of [the defendant]. Second, records relating to whether any omission [was made] on [a form] completed was material to [USCIS] appear now to have been lost or destroyed as a result of the passage of time. The prejudice in this case is all the more severe because it is not simply [the defendant]’s liberty on the line; rather, if convicted he will be stripped of his United States citizenship. Because of this actual prejudice and because the government has no investigative justification for the 9.5 years it waited to bring this charge, the Court should dismiss the indictment for prejudicial pre-indictment delay in violation of [the defendant’s] Fifth Amendment due process rights.419 This case involved a 35-year-old man from Bolivia who legally immigrated to the United States with his family when he was a teenager. After his July 2008 interview with USCIS but before naturalizing in November 2008, he purportedly engaged in criminal conduct, for which he was not convicted until after he had naturalized. He was convicted of breaking a window of a vehicle and stealing two tires. In April 2018, the government arrested him and moved to denaturalize him based on the single fact that he did not update USCIS on his “criminal conduct” prior to taking the Oath of Naturalization. In September 2018, he was denaturalized and a stipulated JRO was entered against him—nearly two decades after he started his life in the U.S. as a teen. Similarly, in the context of civil denaturalizations, defendants have raised a defense of laches, which is based on the maxim that “equity aids the vigilant and not those who slumber on their II. Denaturalization: A Radical Measure in the Hands of Zealots 95