FOR THE DISTRICT OF KANSAS
PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30(b)(6) and 45 and LR
30.1, plaintiff will take the deposition(s) 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 18, 2000. If necessary, each deposition will be adjourned until completed.
Dated: August 4, 2000.
For the period from January 1, 1995 to the present, the information contained in the GET SMART reports regularly prepared by American, including the components and calculation of PAX R/ASM," DEC R/ASM" and TTL R/ASM" of "ADJ. C/ASM," "18M C/ASM," "Adjusted M%," and 18M VAR M%", the methodology used in making backcasts and forecasts, the assumptions made in forecasting American's share of nonstop operations and seats, and the basis for the assumption in the 12/12/97 GET SMART report that American would have 100% share of nonstop frequencies and seats in DFW-MCI beginning July 1998.