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 STATEMENT OF OPPOSITION TO AMERICAN'S
                        MOTION IN LIMINE TO EXCLUDE CERTAIN
                      EVIDENCE RELATED TO LEGEND AIRLINES, INC.


       Plaintiff United States hereby opposes American's Motion in Limine to Exclude Certain

Evidence Related to Legend Airlines, Inc. ("Motion in Limine").  American has provided no basis

for excluding the relevant and admissible testimony of Thomas G. Plaskett, the Vice-President and

Vice-Chairman of the Board of Directors Legend Airlines, Inc. ("Legend").  In support of this

Motion, Plaintiff files its accompanying Memorandum and the Declarations of Karl D. Knutsen and

Max Huffman.





OPPOSITION TO AMERICAN'S MOTION IN LIMINE
RELATED TO LEGEND AIRLINES, INC. -- 1



       WHEREFORE, the United States respectfully requests that the Court deny American's

Motion in Limine.

Dated: March 16, 2001

Respectfully submitted,

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.                          ))
AMR CORPORATION,                           )
AMERICAN AIRLINES, INC., and               )
AMR EAGLE HOLDING                          )
CORPORATION,                               ))
                       Defendants.         )


                               DECLARATION IN SUPPORT OF
      UNITED STATES' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL

1.     My name is Craig W. Conrath.  I am the lead lawyer for the United States in the above-

captioned litigation.  I submit this declaration in support of the United States' Opposition to

Motion to Compel.

2.     On or about September 3, 1999, I spoke with counsel for defendants about Interrogatory No.

2, which requires the United States to provide a recitation, on a witness-by-witness basis, of the

supplied by each witness to Department of Justice ("DOJ") attorneys conducting law enforcement

investigations in anticipation of litigation.  I explained the United States' view that the

seeks material protected by the work product doctrine.  I also indicated my awareness of the recent

decision involving this issue, United States v. Dentsply, Int'l, Inc.  At no time in this

other conversation with defendants' counsel, did I indicate a willingness answer the interrogatory

without objection.



3.     During this conversation, and on at least two other occasions, I asked counsel for

it was their position that interrogatories seeking witness-by-witness recitation of attorney

such as Interrogatory No. 2, are standard practice in Kansas, and if so, whether they would send us

copies of such interrogatories that American's local counsel had answered without a work-product