The following excerpt is from U.S. v. Sharif, 878 F.2d 387 (9th Cir. 1989):
"[T]he necessity requirement is not intended to relegate the use of wiretaps to that of last resort." United States v. Brown, 761 F.2d at 1275. Law enforcement officers need not exhaust every conceivable investigative technique before seeking authority to intercept telephone communications. United States v. Brone, 792 F.2d at 1506. In evaluating the government's showing, "the reviewing court should use a standard of reasonableness." United States v. Ippolito, 774 F.2d at 1486.
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