Motion to Enter Order Terminating Final Judgment

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Plaintiff United States of America moves this Court to enter an Order terminating the Final Judgment in the captioned matter, and in support of this motion, states as follows:

1. On November 12, 1999, Morgan Drive Away, Inc. (Morgan) moved to terminate the Final Judgment entered by this Court on June 30, 1976.

2. The United States tentatively agreed to the termination subject to the following conditions:

1. that Morgan publish at its own expense a notice of the motion, the reasons therefor, and the opportunity to file comments thereon, in two consecutive issues of (1) The Wall Street Journal and (2) Manufactured Home Merchandiser, and file proof of such publications with the Court;
2. that the United States publish a notice of the motion, the reasons therefor, and the opportunity to file comments thereon, in the Federal Register;
3. that copies of all comments received by the United States within sixty (60) days of the last publication of notices, and the United States' response thereto, be filed with the Court within a reasonable period; and
4. that the Court would not rule upon the motion before the seventieth (70th) day following the last publication of notices.

3. The United States did not receive any comments within the 60-day comment period and therefore did not file any response to comments.

4. As of the date of this motion, all of the foregoing conditions have been fulfilled.

A proposed Order Terminating the Final Judgment is attached hereto.

Respectfully submitted,

FOR PLAINTIFF
UNITED STATES OF AMERICA

Dated: April 12, 2000