In Berger v. New York, 388 U.S. 41, 54, 87 S.Ct. 1873, 18 L.Ed.2d 1040 (1967) the Supreme Court invalidated New York's eavesdropping law on Fourth Amendment particularity grounds because it authorized the ex parte issuance of wiretap and "bugging" warrants merely on the basis of a law enforcement official's affidavit swearing that he or she had a "`reasonable ground to believe that evidence of crime may be thus obtained.'" (quoting N.Y.Crim. Proc. Law 813-a) In its decision, the Court noted that the New York law "laid down no requirement for particularity in the warrant as to what specific crime has been or is being committed, nor `the place to be searched,' or `the persons or things to be seized' as specifically required by the Fourth Amendment." Id. at 56, 87 S.Ct. 1873. Finally, and critically important to the present analysis, the Berger Court conceded that "it is true that the statute requires the naming of `the person or persons whose communications, conversations or discussions are to be overheard or recorded'" but concluded that "this does no more than identify the person whose constitutionally protected area is to be invaded rather than `particularly describing' the communications, conversations, or discussions to be seized." Id. at 59, 87 S.Ct. 1873. In Berger v. New York, 388 U.S. 41, 87 S.Ct. 1873, 18 L.Ed.2d 1040 (1967), the necessity of judicial authorization for the trespassory invasion was not at issue because each of the two surreptitious entries which took place was the subject of prior judicial approval. Nevertheless, the Court recognized that protection from unauthorized intrusion into private premises is a primary concern of the Fourth Amendment. It outlined some of the safeguards present in other cases where it had held the Amendment's requirements met. Among these protections were: issuance of a warrant allowing one limited intrusion rather than a series of intrusions or continuous surveillance; issuance of a warrant drawn to foreclose any search of unauthorized areas; and obtaining of a new order on a new showing of probable cause, by officers seeking to resume the search. In Berger the Court was concerned with the question whether the challenged New York statute was facially invalid in that it permitted the second aspect of the search the overhearing to be undertaken by general warrant, contrary to the Amendment's command. It was suggested that unconsented entry without notice might be permitted on a showing of exigent circumstances, and that one of the defects of the New York law in question was that it did not require such a demonstration prior to issuance of an eavesdropping warrant.