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1
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STIPULATION PROTECTIVE ORDER REGARDING EXPERT DISCOVERY
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EXTRACTED KEY WORDS
PARTIES STIPULATION DISCOVERY DISCLOSURES MATTER COMPUTER PROGRAMS TESTIMONY OPINIONS PARTY DRAFT GUIDELINES UNITED STATES AMR SCOPE CONNECTION COUNSEL RELATING DISCLOSURE REQUIREMENTS REPORTS BUSINESS DEPOSITION WRITINGS ASSISTANTS SUPPORT STAFF NON-TESTIFYING CONSULTANTS ATTORNEYS PARTY OFFERING RELYING |
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.
STIPULATION AND PROTECTIVE ORDER
REGARDING EXPERT DISCOVERY
The parties hereto, through their respective counsel of record, hereby stipulate to the
regarding the scope of expert discovery and testimony relating to experts in this matter:
1. In order to avoid consuming the parties' and the Court's time and resources on
discovery issues relating to experts, the parties have agreed to certain limitations on the scope of
expert-related discovery and testimony in this matter. Neither the terms of the stipulation nor the
parties' agreement to them implies that any of the information restricted from discovery in this
would otherwise be discoverable.
2. The parties will make all disclosures required by Rule 26(a)(2)(B), as modified or
limited by this Stipulation, at the times provided by this Court for the service of written expert
The parties will supplement such disclosures at least three (3) business days before an expert's
deposition. To the extent that the disclosures include exhibits, information or data processed or
modeled by computer at the direction of a disclosed expert in the course of forming the expert's
opinions, machine readable copies of the data along with the appropriate computer programs and
instructions shall be produced, provided that no party need produce computer programs that are
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2
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PLAINTIFFS MOTION FOR RECONSIDERATION COURT ORDER
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EXTRACTED KEY WORDS
UNITED STATES RECONSIDERATION PLAINTIFF UNITED STATES HOVENKAMP ANTITRUST COURT ORDER GRANTING DEFENDANTS REVIEW HERBERT COST GOVERNMENT FOOTNOTE FIRST TIME AIRPLANE DEPRECIATION OBSOLESCENCE VARIABLE COST EMPHASIS SUPPORT PLAINTIFF FILES ACCOMPANYING MEMORANDUM DECLARATION 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 ) FILED OCT 23, 2000
AMR EAGLE HOLDING )
CORPORATION, ))
Defendants. )
_________________________________)
PLAINTIFF'S MOTION FOR RECONSIDERATION
OF THE COURT'S SEPTEMBER 28, 2000,
ORDER GRANTING DEFENDANTS' MOTION TO REVIEW
Plaintiff United States hereby moves, pursuant to D. Kan. Rule 7.3, for reconsideration of
of the Court's Order Granting Defendants' Motion to Review Magistrate Judge Humphreys'
decision of June 13, 2000 (filed September 28, 2000) ("September 28 Order"). The United
States respectfully requests that the Court modify its September 28 Order to correct the mistaken
implication that Professor Hovenkamp revised his treatise, PHILLIP E. AREEDA & HERBERT
HOVENKAMP, ANTITRUST LAW: AN ANALYSIS OF ANTITRUST PRICIPLES AND
THEIR APPLICATION (Supp. 1999), after consulting with the government by "adding a
footnote which suggesed for the first time that the entire cost of an airplane (in addition to
depreciation and obsolescence) should be considered a variable cost." (Emphasis added).
PLAINTIFF'S MOTION FOR RECONSIDERATION -- 1
In support of this Motion, Plaintiff files its accompanying Memorandum and the
Declaration of Herbert Hovenkamp.
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