The following excerpt is from U.S. v. Couch, 688 F.2d 599 (9th Cir. 1982):
9 Although a warrant or court order is not required, the agents in this case followed the procedure endorsed in United States v. Aman, 624 F.2d 911, 912-13 (9th Cir. 1980) and United States v. Cameron, 538 F.2d 254, 258-59 (9th Cir. 1976), and obtained a court order.
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