The following excerpt is from U.S. v. Alvarez, 810 F.2d 879 (9th Cir. 1987):
The government argues that obtaining a telephone warrant is not an easy task, and it points to our decision in United States v. Good, 780 F.2d at 775. But our decision here does not invariably require the government to have a telephone warrant before it moves in on a dangerous suspect. It simply requires the government either to attempt, in good faith, to secure a warrant 6 or to present evidence explaining why a telephone warrant was unavailable or impractical. Id.
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