The memorandum noted that a number of Federal programs had not been authorized by Congress.

Also, a memorandum from the American Embassy noted that "gunshots in and around San Salvador are a regular occurrence."

Nevertheless, Mr. Ruff, who became counsel in February, decided to release the memorandum notes last week.

A memorandum in support of the bill noted "the lack of standards in determining eligibility for release."

In a footnote, the memorandum noted that in the impeachment cases of three judges dating from before 1936 there were two separate votes.

The memorandum notes that open software presents a threat to Microsoft because of its ability to mobilize thousands of programmers.

Mr. Ames "was sparing no expense" renovating and redecorating the house, the memorandum noted.

Perutz soon proposed a solution and in a footnote his memorandum noted that:

The memorandum noted that several hundred students had recently protested the presence of military recruiters at a career fair and demanded that they leave.

But the new memorandum also noted that physical suffering was difficult to define.