disagreement is, however, a very narrow one. We agree, given the policy concerns that animate PACA and the general record-keeping requirements set forth in the regulations, see, e.g., 7 C.F.R. §§ 46.14, 46.15, that, in the absence of a writing, there is a presumption against finding that a shipper either has consented to dumping or has agreed that no certification for dumping is necessary. Cf. Jameson v. Valerio’s Produce Co., 46 Agric.Dec. 653, 1985 WL 62906, at *3 (1985) (indicating that proof of dumping rule is intended to protect shippers and growers of produce and holding that, although there therefore is a presumption against waiver, oral waivers of the proof of dumping requirement are per missible); Bagley Produce Co. v. Simpson, 39 Agric.Dec. 456, 1980 WL 21163, at *2 (1980) (<HOLDING>). As the above cases illustrate, however, the
holding that a district court did not clearly err in finding consent where two agents testified that the defendant orally consented but the defendant denied having orally consented and would not sign a written consent form holding that because the individual was being illegally detained when he consented to the search of his luggage that  consent was tainted by the illegality holding that defendants consent was involuntary where defendant consented to search following a warrantless entry and officers explained that absent consent the officers would obtain a warrant holding that shipper acquieseed in the dumping of produce because unrebutted evidence established that shippers agent consented to dumping no written agreement evincing such consent was produced or mentioned holding that insurance agents owe no duty to procure coverage for persons with no written or oral agreement with the agent to procure coverage or who have never contacted the agent about insurance coverage