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V4 eC Mr. Nathan et ‘| JOHN EDGAR HOOVER } + tir. olsen... . DIRECTOR Imy, DAwveords .. i? . . Lir. Chee .... 0. U.S. Bureau of Iuvestination “a a BPepartment of Justice HHC: EM Pashington, B. €. Januery 11, 1933. Suggestion #84 C. A. Appel MEMORANDUM FOR THE DIRECTOR. Employee suggests the inclusion of information in the Menual of Instructions in Section 9, page 5, at the end of the statement in regard to United States versus Holte which will show the citation of the decision in the case Gebardi versus United States, concerning which the Supreme Court recently hanced a; down a decision. * wd The employee offered the phraseology, which the Committee approves, anc if you approve this suggestion, it is recommended that there be added at the end of the statement in regard to the of United States versus Holte, Section 9, page 5 of the Manuel of Instructions, a paragraph reading as follows: 2 "The Supreme Court in the case of Jack G C and Louise Rolfe Gebardi vs. United State ry ay p 2. foe ebar eB, Case #97, October Term, 1932, reversed a conviction for conspiracy on the growmd that L the evidence in that case was insufficient to show that the woman conspired, and as she was ; not guilty, there being no other party, the ~ man could not be guilty of conspiracy. The facts show that she agreed to the transporta- tion without active assistance." & . # a ~ f Respectfully, C. A. Tolson