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1
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PLAINTIFF CERTIFICATE OF CONFERENCE
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EXTRACTED KEY WORDS
CID ASTA COUNSEL UNITED STATES CONFERENCE PLAINTIFF CONSENT DISCLOSURE CERTIFICATE AMERICAN RESPONSE CONNECTION PRIVILEGE LOG INTERNAL DRAFTS ANALYSES RELATING SURVEY COMMISSION OVERRIDES ABSENCE DEFENDANTS KNOWING ATTORNEYS REPRESENTING AMERICAN RAISE REBEKAH FRENCH UNITED STATES DEPARTMENT JUSTICE ANTITRUST DIVISION SUITE WASHINGTON |
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. )
_____________________________ ___ )
PLAINTIFF'S CERTIFICATE OF CONFERENCE
1. On June 15, 2000, the undersigned counsel for Plaintiff telephoned Edward Soto,
counsel for American, and informed him that ASTA had refused to consent to Plaintiff's
disclosure of certain materials produced by ASTA in connection with CID No. 12482.
2. Plaintiff's counsel described the materials at issue, which consist of a privilege
prepared in connection with ASTA's response to CID No. 12482, responses to the two
interrogatories posed by CID No. 12482, and internal drafts and analyses relating to a 1994
survey of commission overrides and incentives conducted by ASTA and produced in response to
one of the two document requests contained in CID No. 12482.
3. Plaintiff's counsel explained that, in the absence of ASTA's consent, we had
determined that Plaintiff could not disclose the CID materials at issue. Plaintiff's counsel asked
whether Defendants, based on the general description of the CID materials and knowing that
PLAINTIFF'S CERTIFICATE OF CONFERENCE
ASTA had refused to consent to their disclosure, intended to insist that the United States produce
those materials.
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