FOR THE DISTRICT OF KANSAS
PURSUANT TO FED. R. CIV. P. 30(b)(6)
PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30(b)(6) and 45 and LR 30.1, plaintiff will take the depositions upon oral examination, to be recorded by stenographic means and videotape, at the offices of the Antitrust Division of the Department of Justice, Thanksgiving Tower, 1601 Elm Street, Suite 4950, Dallas, Texas 75201, of American Airlines, Inc. and AMR Eagle Holding Corporation (collectively "American"). American is requested to designate the person or persons most knowledgeable and prepared to testify on behalf of American concerning the subject matter described on Attachment A hereto. The deposition(s) will commence at 9:00 a.m. on August 31, 2000. If necessary, each deposition will be adjourned until completed.
Dated: August 28, 2000
COUNSEL FOR PLAINTIFF UNITED STATES
(1) American's sales and marketing efforts relating to the reinstatement of nonstop service between Dallas Ft. Worth and Long Beach in January of 1997, including: (a) proposed or actual incentive programs offered to travel agencies; (b) proposed or actual direct mailings targeted at Aadvantage members in the Long Beach area; (c) inaugural day festivities; (d) proposed or actual print, radio or television advertising in the Long Beach area; and (e) the bases for American's statement to the press that it had been "hoping to return to Long Beach for some time now."