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UNITED STATES DISTRICT COURT
FOR THE
EASTERN DISTRICT OF OKLAHOMA



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

CITY OF STILWELL, OKLAHOMA,   
ET AL.,

                  Defendants.


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Case No. CIV 96-196 B


SUPPLEMENT TO UNITED STATES' MOTION TO
COMPEL PRODUCTION OF CERTAIN ORIGINAL AUDIO TAPES

On February 24, 1998, the United States filed a motion to compel defendantsto produce certain original audio tapes for use at trial. In their opposition,defendants suggested that they did not need to produce the tapes, in part, becausethey were "agreeable to allowing" the United States "reasonable access to[defendants’] records and documents, including the original tapes." See Defs.Response at 6 (filed March 3, 1998). In considering the motion to compel, the Courtshould be aware, as evidenced by the attached letters, that defendants have nowrefused the United States access to inspect any tapes of their city council or utility board meetings, even though such tapes are otherwise publicly available underStilwell’s own City Charter. See Art. XI, § 123(b).


Respectfully submitted,

_____________________________
John R. Read
Michele B. Cano
Michael D. Billiel
Attorneys
United States Department of Justice
Antitrust Division
325 Seventh Street, N.W., Suite 500
Washington, D.C. 20530
(202) 307-0468

March 15, 2004