What is the burden of proving that the government has probable cause for forfeiture of a parcel of property?

5 Once the government has made its probable cause showing, the burden shifts to the claimant to demonstrate that the factual predicates for forfeiture have not been met. United States v. One Parcel of Property Located at 15 Black Ledge Drive, 897 F.2d 97, 101 (2d Cir.1990). "The claimant must prove either that the property was not used unlawfully, or that the illegal use was without the claimant's knowledge or consent." Livonia Road, 889 F.2d at 1267.