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1
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ROGER FONES IN SUPPORT OF PLAINTIFFS MOTION FOR RECONSIDERATION COURT ORDER
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EXTRACTED KEY WORDS
DECLARATION MOTION SUPPORT REVIEW ROGER FONES RECONSIDERATION ORDER GRANTING DEFENDANTS UNITED STATES COURT TELEFAX EUROPE JUSTICE DUTIES SUPERVISING TRIAL STAFF WORKING AMERICAN PERSONAL KNOWLEDGE TESTIFY THERETO MAGISTRATE JUDGE HUMPHREYS JOEL KLEIN RECEIVING MISTAKEN IMPRESSION LEAVING MEMORANDUM PENALTY PERJURY FOREGOING |
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 )
AMERICAN EAGLE HOLDING )
CORPORATION, ))
Defendants. )
____________________________________)
DECLARATION OF ROGER W. FONES IN SUPPORT
OF PLAINTIFF'S MOTION FOR RECONSIDERATION
OF THE COURT'S SEPTEMBER 28, 2000,
ORDER GRANTING DEFENDANTS' MOTION TO REVIEW
I, Roger W. Fones, hereby declare as follows:
1. I am the Chief of the Transportation, Energy, and Agriculture ("TEA) Section of the
Antitrust Division of the United States Department of Justice. My duties in this position include
supervising the trial staff working on the United States' case against American. I make this
declaration in support of Plaintiff's Motion For Reconsideration of the Court's September 28, 2000,
Order Granting Defendants' Motion to Review. I have personal knowledge of the matters set forth
herein, unless otherwise stated, and could and would testify thereto if called upon to do so.
2. On October 5, 2000, I called Professor Hovenkamp to inform him that the Court had
issued an Order Granting Defendants' Motion to Review the Protective Order issued by Magistrate
DECLARATION OF ROGER W. FONES IN SUPPORT
OF PLAINTIFF'S REPLY - 1
Judge Humphreys ("September 28 Order" or "Order"), thus allowing Defendants to retain copies of
Professor Hovenkamp's October 2, 1998, letter to Joel Klein ("Hovenkamp Letter"). I explained that
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2
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NOTICE OF DEPOSITION 8-4-00 6
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EXTRACTED KEY WORDS
UNITED STATES R/ASM DISTRICT COURT AMERICAN AIRLINES DEPOSITION PURSUANT COUNSEL YORK PLAINTIFF ANTITRUST DIVISION JUSTICE SUITE REPORTS C/ASM FORECASTS NONSTOP SEATS WASHINGTON CALCULATION PAX R/ASM TTL R/ASM ADJ VAR METHODOLOGY BACKCASTS BASIS NONSTOP FREQUENCIES DFW-MCI |
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. )
______________________________)
NOTICE OF DEPOSITION PURSUANT TO
FED.R.CIV.P. 30(B)(6)
TO: CLERK OF THE COURT
COUNSEL FOR DEFENDANTS
Helene Jaffe
Weil Gotshal & Manges L.L.P.
767 Fifth Avenue
New York, New York 10153
PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30(b)(6) and 45 and LR
30.1, plaintiff will take the deposition(s) upon oral examination, to be recorded by
stenographic means and videotape, at the offices of the Antitrust Division of the
Department of Justice, Thanksgiving Tower, 1601 Elm Street, Suite 4950, Dallas, Texas
75201, of American Airlines, Inc. and AMR Eagle Holding Corporation (collectively
"American"). American is requested to designate the person or persons most
knowledgeable and prepared to testify on behalf of American concerning the subject
matter described on Attachment A hereto. The deposition(s) will commence at 9:00 a.m.
on August 18, 2000. If necessary, each deposition will be adjourned until completed.
Dated: August 4, 2000.
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