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1
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US OPPOSITION TO DEFENDANTS MOTION TO COMPEL DOCUMENTS CRAIG CONRATH
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EXTRACTED KEY WORDS
AMERICAN DECLARATION NW/CO MOTION CRAIG CONRATH SUPPORT COMPEL DOCUMENTS AIRLINES MONOPOLIZATION PROTECTIVE ORDER COUNSEL UNITED STATES DISTRICT EXHIBIT PREDATORY NORTHWEST OPP HUB INVESTIGATIONS MATTER STATES DISTRICT COURT VIOLATIONS SHERMAN ACT RELATING JUDGE MEET-AND-CONFER PROCESS COMPLAINT ALLEGATIONS PARTICIPATION |
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 CRAIG W. CONRATH IN SUPPORT
OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION
TO COMPEL DOCUMENTS RESPONSIVE TO AMERICAN'S
FIRST AND SECOND REQUESTS FOR DOCUMENTS
I, Craig W. Conrath, declare as follows:
1. I am the lead lawyer for the United States in the above-captioned litigation. I submit
declaration in support of the United States' Opposition to Defendants' Motion to Compel.
2. On October 23, 1998, the United States filed suit against Northwest Airlines Corp.
("Northwest") and Continental Airlines, Inc. ("Continental") in the United States District Court
Eastern District of Michigan. In its suit, the United States seeks to enjoin Northwest's purchase
controlling interest in Continental. A true and correct copy of the Complaint filed in United
Northwest Airlines, Corp., et al ("NW/CO") is attached as Exhibit 1. This complaint does not
DECLARATION OF CRAIG W. CONRATH IN SUPPORT
OF OPP. TO MOTION TO COMPEL DOCUMENTS - 1
any claims alleging violations of Section 2 of the Sherman Act, 15 U.S.C. § 2 (relating to
monopolization); rather, NW/CO involves alleged violations of Section 7 of the Clayton Act (15
§ 18) (relating to mergers and acquisitions) and Section 1 of the Sherman Act (15 U.S.C. § 1)
to anticompetitive agreements). NW/CO does not involve any allegations of predatory conduct by
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