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Memorandum to Mr. Adams Re: HEARNAP pr obable cause is a matter requiring a good deal of subjective judgment and though I knew of no case which held that an anonymous tip alone is sufficient for probable cause, there are numerous cases Where anonymous tips have been used as elements of probable cause and the judgment of the sufficiency of probable cause is determined by the degree of corroboration of the allegation in the anonymous tip. RECOM MENDATION: For information.