D.N.J.: Foreign wiretap complied with their law so it was reasonable for 4A purposes; GFE also applied

“While it is clear that a joint venture has not been adequately alleged by Escalante-Melgar, even if a joint venture is assumed in this case, evidence obtained from the Salvadoran wiretaps would still be admissible. … Here, there is no assertion that the prosecutors in El Salvador did not comply with their country’s law in obtaining the wiretaps at issue. In fact, the wiretaps were approved by a judge in El Salvador who reviewed the wiretap application submitted by Salvadoran prosecutors and found that the wiretap application met the legal requirements under the laws of El Salvador. … As the Fourth Amendment’s reasonableness test is met here, evidence obtained from the Salvadoran wiretaps would be admissible even if a joint venture did exist. [¶] Finally, even if a showing had been made that a joint venture existed and that the laws of El Salvador were not followed such that the wiretaps did not meet the Fourth Amendment’s reasonableness test, evidence obtained from the wiretaps would still be admissible under the good faith exception to the Fourth Amendment.” United States v. Escalante-Melgar, 2020 U.S. Dist. LEXIS 34850 (D.N.J. Feb. 28, 2020).