The following excerpt is from U.S. v. Ames, 106 F.3d 409 (9th Cir. 1997):
Fifth Amendment analysis is unnecessary, because the delay is post-indictment. Post-indictment delay is subject to the more stringent Sixth Amendment standard. United States v. Sandoval, 990 F.2d 481, 485 n. 8 (9th Cir.1993).
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