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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
PROCEDURES FOR TERMINATION OF FINAL JUDGMENT
Plaintiff United States of America and Defendant AT&T Corporation ("AT&T," the successor in interest to Tele-Communications, Inc.) and Liberty Media Corporation ("Liberty") move this Court to enter an order establishing procedures for the termination of the Final Judgment entered in this case, and in support of this motion, state as follows:
1. Plaintiff United States of America and Defendant AT&T and Liberty have entered into a Stipulation to terminate the Final Judgment entered by this Court on August 23, 1999. The United States has provisionally agreed to the termination. However, the United States as a matter of policy does not consent to the termination of judgments without public notice and an opportunity for public comment.
2. Therefore, the parties have agreed in the Stipulation to procedures providing all potentially interested persons with adequate notice that a proposed termination of this Final Judgment is pending, adequate notice of the reasons in support of the proposed termination, and an adequate opportunity to comment. See United States v. Swift & Co., 1975-1 Trade Cas. (CCH) ¶ 60,201 at 65,703 (N.D. Ill. 1975) (identifying these as minimum requirements when considering judgment modification).
3. The United States, AT&T and Liberty have agreed that AT&T and Liberty will publish notice at their expense.
Therefore, the United States, AT&T and Liberty move the Court to order:
FOR PLAINTIFF THE UNITED STATES OF