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1
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US RESPONSE TO AMERICANS SUBMISSION REGARDING REMEDY
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EXTRACTED KEY WORDS
REMEDY AMERICAN STANDARD LIABILITY COURT VIOLATION SUBMISSION LEGAL STANDARD EVIDENCE RESPONSE ROUTE COST MONOPOLIZATION CAPACITY LIABILITY DETERMINATION SUMMARY JUDGMENT REVENUES SOF SHERMAN ACT VARIABLE COST PREDATORY MOTION POWER COMPETITORS LCCS SOUND DISCRETION FASHIONING CONFERENCE LAW |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
_________________________________)
UNITED STATES OF AMERICA, ))
Plaintiff, )) Civil Action No.: 99-1180-JTM
v. ))
AMR CORPORATION, )
AMERICAN AIRLINES, INC., and )
AMR EAGLE HOLDING )
CORPORATION, ))
Defendants. )
_________________________________)
UNITED STATES' RESPONSE TO AMERICAN'S
SUBMISSION REGARDING REMEDY
I. INTRODUCTION
As we understood it from Magistrate Judge Humphreys, the Court has already expressed a
preference to address the issue of remedy after it has made its liability determination. The
1
States concurs with the Court's view and submits this brief response to Defendants' (collectively
"American") submission to the Court regarding remedy. What appears to be at the root of
American's submission is its desire to pre-argue to the Court the merits of American's defenses
1/19/01 Pretrial Conf. Trans., at 22:13-19 (emphasis supplied) ("I think there will
1
further discussion with counsel with Judge Marten about it, but as we discussed it yesterday in
anticipation of the conference today, I think he feels that the liability stage of the case is
going to have to go forward. Until there is any proof of liability, the remedy issue doesn't really
rise to a level of proof.").
UNITED STATES' RESPONSE TO AMERICAN'S
SUBMISSION REGARDING REMEDY -- 1
on the ultimate issue of liability.
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2
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KARL KNUTSEN IN SUPPORT OF US OPPOSITION TO AMERICANS MOTION IN LIMINE
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EXTRACTED KEY WORDS
UNITED STATES DISTRICT DECLARATION PLASKETT MOTION LIMINE KARL SUPPORT OPPOSITION LEGEND DEPOSITION COUNSEL PEARLSTEIN DISTRICT COURT AIRLINES NORTHERN DISTRICT TEXAS ROTHMAN TESTIMONY VOICE-MAIL MESSAGE INTENTION SEEKING DISCOVERY ANTICIPATED FILING PRECLUDE PENALTY PERJURY FOREGOING COLUMBIA |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
)
UNITED STATES OF AMERICA, ))
Plaintiff, )) Civil Action No.: 99-1180-JTM
v. ))
AMR CORPORATION, )
AMERICAN AIRLINES, INC., and )
AMR EAGLE HOLDING )
CORPORATION, ))
Defendants. )
______________________________ )
DECLARATION OF KARL D. KNUTSEN IN SUPPORT OF PLAINTIFF'S
OPPOSITION TO AMERICAN'S MOTION IN LIMINE TO EXCLUDE CERTAIN
EVIDENCE RELATED TO LEGEND AIRLINES, INC.
I, Karl D. Knutsen, hereby declare as follows:
1. I am an attorney in the Antitrust Division ("Division") of the United States
Department of Justice and am a member of the trial staff working on the United States' case
against American. I make this declaration in support of Plaintiff's Opposition to American's
Motion in Limine. I have personal knowledge of the matters set forth herein and can and will
testify thereto if called upon to do so.
2. I was present at the deposition of Mr. Thomas G. Plaskett, taken on November 6-
7, 2000, by American, when Mr. Plaskett's counsel instructed Mr. Plaskett not to answer
questions related to documents that Magistrate Judge Sanderson of the Northern District of Texas
refused to order Legend to produce to American.
3. After the deposition I telephoned Richard Rothman, counsel for American, and
asked whether American intended to return to the District Court for the Northern District of
Texas to seek additional documents from Legend and/or to compel the testimony of Mr. Plaskett.
Mr. Rothman told me that he would have Debra Pearlstein, also counsel for American, respond to
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