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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA


UNITED STATES OF AMERICA,
                 
                  v.

MITSUBISHI CORPORATION,          

                           Defendant.

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Criminal No. 00-033

Judge Marvin Katz

Violations: 15 U.S.C. 1 and 18 U.S.C. 2(a)

Filed: 02-06-01

MEMORANDUM OF THE UNITED STATES IN RESPONSE
TO DEFENDANTS MOTION CONCERNING COLLUSION
BY JAPANESE MANUFACTURERS IN THE 1980'S

The United States intends to limit its questioning of Robert Krass to his knowledge concerning Mitsubishi and its role in aiding and abetting the conspiracy. Accordingly, the Government does not oppose the defendant's motion.

The Government notes, however, that it has been the defendant which has introduced evidence of "rumors" of price-fixing in the 1980's. Should the defendant pursue this area on cross-examination of Mr. Krass, the Government does intend to address his knowledge on this subject on redirect.

Dated:

  ________________________________
ROBERT E. CONNOLLY
JOSEPH MUOIO
WENDY BOSTWICK NORMAN
ROGER L. CURRIER
Attorneys, Philadelphia Office
Antitrust Division
U.S. Department of Justice
The Curtis Center, Suite 650W
170 S. Independence Mall West
Philadelphia, PA 19106
Tel. No.: (215) 597-7401


IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA


UNITED STATES OF AMERICA,
                 

                  v.

MITSUBISHI CORPORATION,          

                           Defendant.

|
|
|
|
|
|
|
|
|
|
|         
Criminal No. 00-033

Judge Marvin Katz

Violations: 15 U.S.C. 1 and 18 U.S.C. 2(a)

Filed: 02-06-01

CERTIFICATE OF SERVICE

This is to certify that on the day of 6th February 2001, a copy of the Memorandum of the United States In Response to Defendants Motion Concerning Collusion by Japanese Manufacturers in the 1980's has been hand delivered to counsel of record for the defendant as follows:

Theodore V. Wells, Esquire
Paul Weiss Rifkind Wharton & Garrison
Rittenhouse Hotel, Room 1306
210 West Rittenhouse Square
Philadelphia, PA 19103

 ________________________
ROBERT E. CONNOLLY
Attorney, Philadelphia Office
Antitrust Division
U.S. Department of Justice
The Curtis Center, Suite 650W
170 S. Independence Mall West
Philadelphia, PA 19106
Tel. No.: (215) 597-7405