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1
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Government Exhibit # 2ND AMENDED COMPLAINT
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EXTRACTED KEY WORDS
PLAINTIFFS DEFENDANTS CLEAN FLICKS VIEWING MOVIES THIRD PARTY EDITS HUNTSMAN THIRD PARTY COURT COLORADO STUDIOS TECHNOLOGIES AUDIENCE VIEWER MEMBERS ACT ENTERTAINMENT PICTURES DECLARING EDITING INFRINGEMENT BUSINESS PATENT DISTRICT RELATING LLC LAWSUIT DIRECTORS PRIVATE HOME VIEWING |
THE UNlTED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
ivjl Action No. 02-M-1662 (MJW)
OBERT HUNTSMAN and
LEAN FLICKS OF COLORADO, L.LC.,
Plaintiff(s), .
IDE0 II,
*LENN DICKMAIN, -
W.D. MANAGEMENT CORJ'ORpiTION,
RILOGY STTJDIOS, INC.,
LEAN-FLICKS,
l-Y CLEMLICKS,
AMlLY SHIELD TECHNOLOGIES, LLC,
IEARPLAY, INC.,
LEAN CUT CINBMAS,
AMILY SAFE MEDIA,
DlTMXMOVIES,
/&l.lLY FLIX, U.S.A., UC. and
LAY IT CLEAN VIDEO,
Counterclaim-Defendants,
l-EVEN SODERBERGH,
OBERT ALTMAN,
UCHAEL APTED,
AYLOR HACKFORD,
URTIS HANSON,
ORMAN JEWISON,
M-N LANDIS,
KHAEL MANN,
!lILLIP NOYCE,
R4D SILBERLING,
ETTY THOMAS,
WIN WINICLER,
lAI'XlN SCORSESE,
EVEN SPIELBERG,
3BERT EDFORD,
mEY POLLACK,
ETRO-GOLDWY%MAYER STUDIOS, mC.,
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2
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CERTIFICATE OF SERVICE
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EXTRACTED KEY WORDS
CHRIS-CRAFT INDUSTRIES CONSTANTINE YORK HEREBY CERTIFY PENALTY PERJURY COMPLAINT JUDGEMENT SEPARATE STIPULATION UNITED STATES EXPLANATION CONSENT DECREE PROCEDURES PLACING AFOREMENTIONED DOCUMENTS ABOVE-NAMED PARTIES LLOYD CONSTANTINE PARTNERS ARPS SLATE MEAGHER FLOM LLP TIMES SQUARE |
CERTIFICATE OF SERVICE
I hereby certify under penalty of perjury that copies of the COMPLAINT, FINAL
JUDGMENT, HOLD SEPARATE STIPULATION AND ORDER, and UNITED STATES'
EXPLANATION OF CONSENT DECREE PROCEDURES have been served upon The News
Corporation Limited; FOX Television Holdings, Inc.; and Chris-Craft Industries, Inc., by placing
copies of the aforementioned documents in the U.S. Mail, directed to each of the above-named
parties at the addresses given below, this 11th day of April 2001.
The News Corporation Limited and
FOX Television Holdings, Inc.
c/o Lloyd Constantine
Constantine & Partners
477 Madison Avenue
New York, NY 10022
Chris-Craft Industries, Inc.
c/o Neal Stoll
Skadden, Arps, Slate, Meagher & Flom LLP
Four Times Square
New York, NY 10036
/s/
Carolyn L. Davis
Senior Trial Attorney
United States Department of Justice
Antitrust Division
1401 H Street, N.W.
Suite 3000
Washington, D.C. 20530
(202) 514-5815
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3
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CERTIFICATE OF SERVICE
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EXTRACTED KEY WORDS
DEFENDANTS DISTRICT COURT KANSAS HEREBY CERTIFY OVERNIGHT MAIL MOTION LIMINE MEETING COMPETITION DEFENSE MEMORANDUM SUPPORT THEREOF DEBRA PEARLSTEIN WEIL MANGES YORK ATTORNEY |
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COURT OF KANSAS
UNITED STATES OF AMERICA, ))
Plaintiff, ) Case No. 99-1180-JTM
)
v. ))
AMR CORPORATION, AMR )
AIRLINES, INC. and AMR EAGLE )
HOLDING CORPORATION, ))
Defendants. ))
CERTIFICATE OF SERVICE
I hereby certify that I caused to be served on Defendants' Counsel referenced below, by
hand and via overnight mail on the 2d day of April, 2001, a copy of Plaintiff's Motion in Limine
to Exclude Evidence Related to a Meeting Competition Defense, Memorandum in support
thereof, Appendix of Unreported Decisions, and this Certificate of Service.
Debra Pearlstein
Weil, Gotshal & Manges
767 Fifth Avenue
New York, NY 10153
Tel: (212) 310-8686
Fax: (212) 310-8007
ATTORNEY FOR DEFENDANTS
By /"s"/
Mark J. Niefer
Attorney for Plaintiff
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4
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REPLY IN SUPPORT OF PLAINTIFFS MOTION FOR RECONSIDERATION COURT ORDER
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EXTRACTED KEY WORDS
PROFESSOR HOVENKAMP MOTION AMERICAN AIRCRAFT RECONSIDERATION UNITED STATES SUPPORT ROUTE AIRLINES DECLARATION COURT REVIEW MAGISTRATE JUDGE MARKET OPPORTUNITY COSTS PREDATION MAGISTRATE JUDGE HUMPHREYS CONSISTENT ANTITRUST LAW SUPPLEMENT STATES DISTRICT COURT ORDER GRANTING FIRST TIME VARIABLE COST TEST OWNERSHIP COST OPPOSITION AVERAGE VARIABLE COST ORDER GRANTING DEFENDANTS PLAINTIFF UNITED STATES |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
)
UNITED STATES OF AMERICA, ))
Plaintiff, )) Civil Action No.: 99-1180-JTM
v. )) REDACTED VERSION
AMR CORPORATION, ) FOR PUBLIC FILING
AMERICAN AIRLINES, INC., and )
AMR EAGLE HOLDING )
CORPORATION, ))
Defendants. )
_________________________________)
REPLY IN SUPPORT OF PLAINTIFF'S MOTION
FOR RECONSIDERATION OF THE COURT'S SEPTEMBER 28, 2000,
ORDER GRANTING DEFENDANTS' MOTION TO REVIEW
Plaintiff United States submits this Reply in Support of its Motion for Reconsideration of
the Court's September 28, 2000 Order Granting Defendants' Motion to Review Magistrate Judge
Humphreys' Decision of June 13, 2000 ("September 28 Order"). The issue presented here is not
whether American agrees with Professor Hovenkamp's analysis of relevant costs -- clearly it does
not. Instead, the issue is whether Professor Hovenkamp has consistently maintained that the
ability of an airline to shift aircraft from one market to another means that aircraft costs are
variable (or "avoidable") on a route where predation is alleged. The answer, based on Professor
Hovenkamp's writings since at least 1986, and confirmed by his declaration, is clearly "yes."
American prevailed on its Motion to Review, and the United States no longer seeks the
return of the document which led to filing of that motion; the United States merely seeks a
correction to the public record. Professor Hovenkamp's declaration establishes the existence of
PLAINTIFF'S REPLY IN SUPPORT OF MOTION FOR RECONSIDERATION -- 1 -- REDACTED VERSION
the error in the record and, other than claiming that the declaration is "ambiguous," American
does not dispute the contents of the declaration. American's refusal to accept the sworn
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5
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TRIAL PLAINTIFFREBUTTALARGUMENT
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EXTRACTED KEY WORDS
PLAINTIFF THREAT PHYSICIAN FERRARA WITNESS SAM FEAR DEFENSE UNITED STATES BULLETPROOF VEST DOCTORS LIFE FREE SPEECH TERRORISTS FATHER MOTHER ABORTION COUNTRY NONVIOLENT PROTEST WANTED POSTER PRECAUTIONS BULLETPROOF GLASS CONTEXT DAVID GUNN THREATENS BOMBING ABRAHAM ANDERSON RYDER TRUCK HANDGUN |
1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE DISTRICT OF OREGON
3 PLANNED PARENTHOOD OF THE )
COLUMBIA/WILLAMETTE, INC., et al. )
4 )
Plaintiffs, ) CV 95-1671 JO
5 )
vs. ) January 26, 1999
6 )
AMERICAN COALITION OF LIFE ) Portland, Oregon
7 ACTIVISTS, et al. ))
8 Defendants. )
9
10 TRANSCRIPT OF TRIAL PROCEEDINGS
11 BEFORE THE HONORABLE ROBERT E. JONES
12 PLAINTIFF'S REBUTTAL ARGUMENT
13 UNITED STATES DISTRICT COURT JUDGE, AND A JURY
14 APPEARANCES
15
16
FOR THE PLAINTIFF: CAROL BERNICK
17 Davis Wright Tremaine
1300 S.W. Fifth Ave., Suite 2300
18 Portland, Or 97201
503 778-5233
19
MARIA T. VULLO
20 MARTIN LONDON
ELIZABETH MARINGER
21 Paul, Weiss, Rifkind, etc.
1285 Avenue of the Americas
22 New York, NY 10019-6064
212 373-3346
23
ROGER K. EVANS
24 Planned Parenthood Federation of America
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