1. * I want to thank Jason Leckerman, a recent graduate of the University of Pennsylvania Law School, who provided his usual outstanding research assistance, thoughtful comments and cheerful advice, and Efrem Levy, a talented Penn Law/Wharton student, who contributed helpful editorial suggestions.
2. 1 Congressman Henry J. Hyde of Illinois, chairman of the House Judiciary Committee and chief architect of CAFRA, said that the legislation struck a fair balance between protecting property owners and continuing to permit the government to confiscate assets that it can show may have been part of a crime. See Stephen Labaton, Congress Raises Burden of Proof on Asset Seizures, N.Y. TIMES, April 12, 2000, at A1.
3. 2 Advertisement of the American Civil Liberties Union, N.Y. TIMES MAG., April 29, 2001. See also LEONARD W. LEVY, A LICENSE TO STEAL (1996).
4. 3 971 F.2d 896, 905 (2d Cir.1992). See also United States v. $506,231 in
5. U.S. Currency, 125 F.3d