The following excerpt is from American-Arab Anti-Discrimination Committee v. Reno, 70 F.3d 1045 (9th Cir. 1995):
Although not all rights of criminal defendants are applicable to the civil context, the procedural due process notice and hearing requirements have "ancient roots" in the rights to confrontation and cross-examination. Greene v. McElroy, 360 U.S. 474, 496, 79 S.Ct. 1400, 1413, 3 L.Ed.2d 1377 (1959).
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