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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

FILED JUNE 25, 1996

UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

AMERICAN NATIONAL CAN CO.

and

KMK MASCHINEN AG;

                  Defendant.

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Civil Action No.
Filed

STIPULATION

It is stipulated by and between the undersigned parties, by their respective attorneys, that:

1. The Court has jurisdiction over the subject matter of this action and over each of the parties hereto for purposes of this action, and venue of this action is proper in the District of Columbia;

2. The parties consent that a Final Judgment in the form hereto attached may be filed and entered by the Court, upon the motion of any party or upon the Court's own motion, at any time after compliance with the requirements of the Antitrust Procedures and Penalties Act (15 U.S.C. § 16(b)-(h)), and without further notice to any party or other proceedings, provided that plaintiff has not withdrawn its consent, which it may do at any time before the entry of the proposed Final Judgment by serving notice thereof on defendant and by filing that notice with the Court;

3. Each defendant agrees to be bound by the provisions of the proposed Final Judgment pending its approval by the Court; and

4. In the event plaintiff withdraws its consent or if the proposed Final Judgment is not entered pursuant to this Stipulation, this Stipulation shall be of no effect whatsoever, and the making of this Stipulation shall be without prejudice to any party in this or any other proceeding.

DATED: June 23, 1996

FOR PLAINTIFF:

/S/_______________________________
Anne K. Bingaman
Assistant Attorney General

/S/_______________________________
Joel I. Klein
Deputy Assistant Attorney General

/S/_______________________________
Rebecca P. Dick
Deputy Director of Operations

/S/_______________________________
Mary Jean Moltenbrey
Chief, Civil Task Force

/S/_______________________________
Robert J. Zastrow
Assistant Chief
Civil Task Force

/S/_______________________________
Thomas H. Liddle


/S/_______________________________
Scott A. Scheele
DC Bar No. 429061
Attorneys
U.S. Department of
Justice
Suite 300
Liberty Place Building
325 7th Street, N.W.
Washington, DC 20530


FOR DEFENDANT KMK MASCHINEN AG:

Wilmer, Cutler & Pickering

/S/_______________________________
Rajiv P. Santwan
Vice President
KMK Maschinen AG

By: /S/_____________________________
C. Loring Jetton, Jr.
A Member of the Firm

FOR DEFENDANT AMERICAN NATIONAL
CAN CO.:

McDermott, Will & Emery

By: /S/_____________________________
David Marx, Jr.
A Member Of the Firm