The following excerpt is from U.S. v. Martino, 664 F.2d 860 (2nd Cir. 1981):
7. And the more traditional surveillance techniques need not be exhausted first if they are "impractical" or "costly and inconvenient." United States v. Robertson, 504 F.2d 289, 293 (5th Cir. 1974), cert. denied, 421 U.S. 913, 95 S.Ct. 1568, 43 L.Ed.2d 778 (1975) (undercover agents).
554 F.2d at 530.
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