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B. For an evidentiary hearings to cetexrmine governmental . + yeas : : hr, L asens | responsibility for certain acts.of misconductsendufor dismissal if the government is found to have been ressorsibie’€or sSt .miscon= duct; ¢ . . . . oe Cc. . For a discovery order recuiring full and complete dis- closure of illegal governmental actions perpetrated during the in- vestigation of, searen for, end=srosecution of Erily Montague Hwar- f the government's i 1 investigation and preparation of the instant case. ~ "The events Surroumiing the search for Emily Harris end + her covdegenatts © Witliam Harzis and Patricia Hearst present a mh a ' textbook case of governmental miscor wduc® The F.B.I.’s initial ig, : failure to aporehead the sugitives caused extrere “embarassment | 4 “to the government. The government's response was to intensify the qegarch through the wholesale agostiga of blatantly illecal tactics Sy : ~ ; gard*for.Gonstitutional limits on the exercise of police vsover. Almost every rule intended to protect the sanctity of homes, per- senal efiects and private cozmunications has been flagrantly and arrogantly violated oy State, federal and local government in the course of the hunt for Emily Farris and her co-defendants. - The . government acts were not conzincz to mere acts of harassment: ‘Or to a fev isolated instances in.olving illecal- searches. The ‘facts ti. show a continuous, deliberate ané systematic pattern of illegal - government activities which were directed azainst the defendants: ee ey os Oe rr ye tee et at