to retain his money, he may be entitled to release of the seized funds pending trial. See United States v. James Daniel Good Property, 971 F.2d 1376, 1384 (9th Cir.1992) (providing that if seizure of claimant’s home violated due process, claimant would be entitled to the rents accrued during the illegal seizure), rev’d on other grounds, 510 U.S. 43, 114 S.Ct. 492, 126 L.Ed.2d 490 (1993); see also Krimstock v. Kelly, 306 F.3d 40, 50 (2d Cir.2002) (probable cause of continued validity to retain vehicles held for forfeiture). Finally, we affirm the district court’s grant of the government’s motion to amend its complaint. Leave shall be freely given to amend a complaint when justice so requires. Fed.R.Civ.P. 15; see also Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 9 L.Ed.2d 222 (1962) (<HOLDING>). Medina argues that the motion to amend the
recognizing several reasons to deny leave to amend a complaint holding the district court is not required to grant a plaintiff leave to amend his complaint sua sponte when the plaintiff who is represented by counsel never filed a motion to amend nor requested leave to amend before the district court holding that leave to amend should be freely given unless there is a good reason such as futility to the contrary recognizing that courts freely grant pro se litigants leave to amend holding that leave shall be freely given to amend a complaint is a mandate  to be heeded