What is the level of proof required from the US Government when it seizes mutilated or damaged coins imported from Chinese recycling factories and dump yards, on the suspicion that the coins are forgeries, when it launches a motion to forfeit the coins or when it makes a motion for summary judgment in response to the owner complaint to return coins seized by way of warrants or other seizures, given that there is a differences in approach between the two jurisdictions that normally handle these case (Los Angeles as a port of entry) and Philadelphia (as the situs of the US Mint)

QUESTION PRESENTED (Rule 14.1(a)) I. What is the level of proof required from the US Government when it seizes mutilated or damaged coins imported from Chinese recycling factories and dump yards, on the suspicion that the coins are forgeries, when it launches a motion to forfeit the coins or when it makes a motion for summary judgment in response to the owner complaint to return coins seized by way of warrants or other seizures, given that there is a differences in approach between the two jurisdictions that normally handle these case (Los Angeles as a port of entry) and Philadelphia (as the situs of the US Mint). Il. What qualifies as “probable cause” that is sufficient for the issuance of warrants to seize coins imported from China, given that so far no owner or Petitioner was able to progress any case to the point of receiving discovery and/or cross examining the agents that requested the warrants. . III. Can a trial court rely on an expert metallurgical opinion from someone who works in or for the US Mint, given that in the Philadelphia cases the US Mint expert report was determined to be false (at an oral hearing), and in the herein case in California the US Mint expert wrote that he performed a novel testing technique, which is doubtful whether it has industry standard recognition, and why the courts handling these cases should not appoint a neutral expert or at lease order the US prosecutors to provide the owner with samples so he can arm himself with an expert opinion of his own. 2