What is the basis for a finding of flagrant disregard for the purpose of obtaining a warrant to conduct surveillance of a witness?

The district court also relied on the government's failure to utilize conventional surveillance techniques. The issuing judge adopted the affidavit's explanation of why conventional methods would not be successful, see United States v. Commito, 918 F.2d 95, 98 (9th Cir.1990), cert. denied, --- U.S. ----, 112 S.Ct. 224, 116 L.Ed.2d 181 (1991), and the warrant did not require that the agents engage in any conventional surveillance before the video surveillance could begin. Thus, the agents' failure to use conventional methods is not a violation of the warrant and does not support a finding of flagrant disregard.