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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON DIVISION



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

DAILY GAZETTE COMPANY,

and

MEDIANEWS GROUP, INC.

                  Defendant.


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Civil Action No. 2:07-0329

Judge Copenhaver

Magistrate Judge Stanley

Filed: January 20, 2010



STIPULATION

It is stipulated and agreed by and between the undersigned parties by their respective attorneys, subject to approval and entry by the Court, that:

1. The Court has jurisdiction over the subject matter of this action and over each of the parties hereto, and venue of this action is proper in the United States District Court for the Southern District of West Virginia, Charleston Division.

2. The parties stipulate that a proposed Final Judgment in the form attached as Exhibit 1 may be filed with 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(15 U.S.C. § 16), and without further notice to any party or other proceedings, provided that the United States has not withdrawn its consent, which it may do at any time before the entry of the proposed Final Judgment by serving notice thereof on the Daily Gazette Company and MediaNews Group and by filing that notice with the Court.

3. Defendants shall abide by and comply with the provisions of the proposed Final Judgment, pending the Final Judgment's entry by this Court, or until expiration of the time for all appeals of any Court ruling declining entry of the proposed Final Judgment, and shall, from the date of the signing of this Stipulation by the parties, comply with all the terms and provisions of the proposed Final Judgment as though the same were in full force and effect as an order of the Court.

4. This Stipulation shall apply with equal force and effect to any amended proposed Final Judgment agreed upon in writing by the Parties and submitted to this Court.

5. If (1) the proposed Final Judgment is not entered pursuant to this Stipulation and the time has expired for all appeals of any court ruling declining entry of the proposed Final Judgment, or (2) the United States has withdrawn its consent, and the Court has not otherwise ordered continued compliance with the terms and provisions of the proposed Final Judgment, then the Parties are released from all further obligations under this Stipulation and the making of this Stipulation shall be without evidentiary prejudice to any party in this or any other proceeding.

PLAINTIFF UNITED STATES


By: _s/ Stephen M. Horn_
Assistant United States Attorney
Attorney for the United States (WVSB 1788)
P.O. Box 1713
Charleston, WV 25326
Telephone: 304-345-2200
Fax: 304-347-5443
Email: steve.horn@usdoj.gov


By:_s/ Bennett J. Matelson_
United States Department of Justice
Antitrust Division
Litigation III
450 5th Street, NW, Suite 4000
Washington, DC 20530
Telephone: 202-616-5871
Fax: 202-514-7308
E-mail: Bennett.Matelson@usdoj.gov
DEFENDANT DAILY GAZETTE
COMPANY

By:_s/ Lee Simowit__
Baker & Hostetler LLP
1050 Connecticut Avenue, NW
Suite 1100
Washington, DC 20036
Telephone: 202-861-1608
Fax: 202-861-1783
E-mail: lsimowitz@bakerlaw.com


By:_s/ Benjamin L. Bailey_
Bailey & Glasser LLP
209 Capitol Street
Charleston, WV 25301
Telephone: (304) 345-6555
Email: bbailey@baileyglasser.com


DEFENDANT MEDIANEWS
GROUP, INC. (now known as
Affiliated Media, Inc.)

By:_s/ Alan L. Marx_
King & Ballow
1100 Union Street Plaza
315 Union Street
Nashville, TN 37201
Telephone: (615) 726-5455
E-mail: amarx@kingballow.com


By:_s/ John R. Hoblitzell_
Kay, Casto & Chaney PLLC
1500 Chase Tower
707 Virginia Street
Charleston, WV 25301
Telephone: (304) 345-8900
E-Mail: jhoblitzell@kaycasto.com

Dated: January 20, 2010