The following excerpt is from U.S. v. Eight Thousand Eight Hundred Fifty Dollars ($8,850.00) in U.S. Currency, 645 F.2d 836 (9th Cir. 1981):
1. Due process requires that procedural safeguards accompany government seizure of private property. Fuentes v. Shevin, 407 U.S. 67 (92 S.Ct. 1983, 32 L.Ed.2d 556) (1972).
2. In most cases, due process requires pre-seizure safeguards. Id. at 90-92 (92 S.Ct. at 1999-2000).
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