ng the issue have also followed the reasoning in Gaviria and permitted the government to proceed by proffer. SeeUnited States v. Whitman , 514 F.Supp. 2d 101, 102 n.1 (D. Me. 2007) (rejecting the defendant's argument that only he had a right to submit evidence at the detention hearing by proffer); United States v. Cabrera–Ortigoza , 196 F.R.D. 571, 574 (S.D. Cal. 2000) (noting "there is no requirement of live testimony by the government at a detention hearing" and holding that amendments to the federal rules requiring the production of witness statements "do not invalidate the use of proffers at a detention hearing"); United States v. Ward , 63 F.Supp. 2d 1203, 1210 (C.D. Cal. 1999) (noting that "both the Government and the defendant may proceed by proffer or hearsay" at a pretrial detention hearing), aff'd , 237 Fed.Appx. 289 (9th Cir. 2007) ; United States v. Alston , 899 F.Supp. 1, 3 n.3 (D.D.C. 1995) (judicial officer has discretion to permit the government to proceed by proffer); United States v. Alonso , 832 F.Supp. 503, 505 (D. Puerto Rico 1993) (same). As the overwhelming amount of federal precedent demonstrates, pretrial detention is constitutionally permissible upon a prompt judicial determination of probable cause as required by Gerstein . Permitting the government to establish probable cause by proffer and hearsay is consistent with the Federal Act and does not violate due process.