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71a B. The Government’s delay in bringing charges did not violate due process “As the Supreme Court stated in United States v. Marion, the statute of limitations is ‘the primary guarantee against bringing overly stale criminal charges.” United States v. Cornielle, 171 F.3d 748, 751 (2d Cir. 1999) (cleaned up) (quoting United States v. Marion, 404 U.S. 307, 322 (1971)). There is a strong presumption that an indictment filed within the statute of limitations is valid. To prevail on a claim that pre-indictment delay violates due process, a defendant must show both that the Government inten- tionally delayed bringing charges for an improper purpose and that the delay seriously damaged the defendant’s ability defend against the charges. See id. This is a stringent standard. “Thus, while the [Supreme] Court may not have shut the door firmly on a contention that at some point the Due Process Clause forecloses prosecution of a claim because it is too old, at most the door is barely ajar.” DeMichele v. Greenburgh Cent. Sch. Dist. No. 7, 167 F.3d 784, 790— 91 (2d Cir. 1999). The Court sees no evidence that the Government’s delay in bringing these charges was designed to thwart Maxwell’s ability to prepare a defense. However, it is enough to say that Maxwell does not make the strong showing of prejudice required to support this sort of claim. Maxwell contends that the Government’s delay in bringing charges has prejudiced her interests because potential witnesses have died, others have forgotten, and records have been lost or destroyed. It is highly speculative that any of these factors would make a substantial difference in her case. Maxwell first points to several potential witnesses who have passed away. These include Jeffrey Epstein DOJ-OGR- 00000134