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Time is not an issue, midnight is a state of mind for some people. Eating before bed on the other hand depends on a lot of things. When trying to lose weight, you may not have much control over the partitioning of those calories, but nothing is out rite proven. I haven't read a ton about it, but I do know it's better to eat something before bed if you have just worked out, because the muscle repair will not start without it, but if you've been inactive, the muscle glycogen is full and when your inactive for approx. 8 hours of sleep, there is nowhere for those calories to go. Also digestion can either interrupt sleep, or sleep may interrupt digestion. My guess would be depending on which your body needs more is what it will focus on.
If your eating a deficit of calories in a day, you may be hard pressed to get to bedtime without having eaten enough. I can say for certain, those who spend the most time on planning and preparation of meals over the course of losing weight or gaining muscle have the most success, and that success is not linear, they are 3-8 times more successful in a 3 month period. So if you need to eat, but have no food, or can't get food until the last possible minute, this will become a chore you can't finish.
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