Issues: (1) Whether a “scheme or artifice to defraud” under the wire fraud statute, 18 U.S.C. § 1343, encompasses an “implied misrepresentation,” or whether the statute requires an express statement that is either false or misleading; and (2) whether a district court may cure a Speedy Trial Act violation by making an after-the-fact finding that the ends of justice outweigh the interests of the criminal defendant and the public for a speedy trial, or whether the court must make the ends-of-justice finding at the time that it grants the continuance.
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