to be unlikely to succeed if tried or [3] to be too dangerous.” This is known as the “necessity requirement,” and it obligates the government in its application for a wiretap to demonstrate that it has considered other methods of investigation and to explain why those methods have proven inadequate for one or more of the three listed reasons. United States v. Mandell, 833 F.3d 816, 821 (7th Cir. 2016). “Despite its name, the necessity requirement “was not intended to ensure that wiretaps are used only as a last resort in an investigation, but rather that they are not to be routinely employed as the initial step in a criminal investigation.’ ” Id. (quoting United States v. McLee, 436 F.3d 751, 762-63 (7th Cir. 2006)); see also United States v. Fudge, 325 F.3d 910, 919 (7th Cir. 2003) (<HOLDING>). Accordingly, the government’s burden in
holding that the evil we are trying to avoid in these cases is the routine use of wiretaps as an initial step in the investigation holding outofcourt statements relating to reasons for investigation are not admissible where the reasons for the investigation are not at issue recognizing that miranda warnings are unnecessary for the investigation of routine traffic offenses holding that a trustee is not required to avoid the initial transfer from the initial transferee before seeking to avoid it and recover from subsequent transferees and noting that this conclusion is consistent with case law that has disallowed automatic recovery from a subsequent transferee following the avoidance of an initial transfer through a stipulated judgment or default when the transferee had not been a party to the underlying avoidance proceeding holding that the commissioners failure to consider one impairment at step two could not constitute reversible error where the commission found at step two that the plaintiffs other conditions were severe and therefore proceeded to step three in the evaluation process