It is stipulated between counsel for the defendant, Bernard L. Segal, and counsel for the United States, Brian M. Murtagh, with the express consent of the defendant, Dr. Jeffrey R. MacDonald, as follows:

No later than November 14, 1975, the United States will supply counsel for the defendant a complete list of all witnesses which the United States plans to call to trial for its case in chief. Further, by that same date, the United States will supply to counsel for the defendant all statements within the meaning of the Jencks Act, 18 U.S.C. 3500, made by those witnesses.

In return, counsel for the defendant will sign appropriate stipulations regarding the chain of custody of all physical evidence listed in all FBI and CID laboratory reports, on the terms and conditions set forth in the attached letter dated November 4, 1975, from Michael J. Malley, counsel for the defendant, to Brian M. Murtagh, counsel for the United States.

This stipulation expressly includes all terms and conditions set forth on pages one (1) and two (2) of the above referenced letter of November 4, 1975. Counsel for the defendant will sign the appropriate stipulations regarding the chain of custody, as soon as counsel for the United States has prepared those documents and the supporting affidavits in the manner set forth in the above-referenced letter.

As set forth in the letter of November 4, 1975, the defendant hereby in no way stipulates or agrees to stipulate to the accuracy of the results of any laboratory tests, nor does the defendant in any way waive his right to cross-examine each and every laboratory technician and investigator about how the evidence was gathered, what tests were run, how they were run and how the results were arrived at.

I have read the above stipulation and the attached letter dated November 4, 1975, and I expressly authorize my counsel, Bernard L. Segal, to enter into this stipulation.