Exhibit 6
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Mr. Neil F. Keehn 2603 Third Street Santa Monica, CA 90405
Dear Mr. Keehn: This letter responds to your January 7, 2003 letter, commenting on the proposed Final Judgment submitted for entry in the captioned case. The government's Complaint in the case charged that the proposed acquisition of TRW Inc. ("TRW") by Northrop Grumman Corp. ("Northrop") would combine one of the only two suppliers of radar and EO/IR payloads for reconnaissance satellite systems sold to the U.S. Government (Northrop) with one of the few companies able to act as prime contractor on U.S. reconnaissance satellite programs that use these payloads (TRW). The Complaint alleges that as a result of this combination, Northrop would have the incentive and ability to lessen competition by favoring its own payload and/or prime contractor capabilities to the detriment or foreclosure of competitors, and would harm the U.S. Government by posing an immediate danger to competition in two current or future programs, the Space-Based Radar and Space Based InfraRed System-Low programs (the latter program is now called the Space Tracking and Surveillance System). Your letter relates exclusively to matters that are not in any way directly related to either the acquisition of TRW by Northrop or the proposed relief. Specifically, you claim that there have been unfair allegations that you were involved in illegal activities during a past employment by TRW. Your letter includes proposed modifications to the Final Judgment, which also relate specifically to your personal claims and not to the subject acquisition or efforts to remedy any competitive problems that it may cause. The purpose of the proposed Final Judgment, and the Complaint on which it is based, is to address the potential lessening of competition that may result from the acquisition of TRW by Northrop. The Final Judgment cannot serve as a vehicle for addressing totally unrelated issues. For this reason, the United States cannot adopt the proposed modifications you have requested. Pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16(d), a copy of your comment and this response will be published in the Federal Register and filed with the Court. However, we will not publish or file the extensive materials that you included with your comment, which do not relate to the issues of this lawsuit.
2603 THIRD STREET n SANTA MONICA, CA 90405 (310) 396-0622 n neilkeehn@yahoo.com January 7,2003
Dear Mr. Kramer, This correspondence is for the purpose of submitting proposed addenda, which are included as Exhibit A, to the above referenced consent decree. In July 2002, I sent a package to Secretary of Defense Rumsfeld as well as to Attorney General Ashcroft. The package sent to Attorney General Ashcroft, received by DoJ on 7/18 via certified mail, is included herein as Exhibit B, and addresses allegations that the former TRW illegally sold a satellite reconnaissance system to the People's Republic of China in which I was allegedly the program manager. The Department of Defense addressed this issue in a competent and professional manner. As a part of its response, DoD informed me that I was perfectly correct in bring this issue to the attention of the Department of Justice. However, I have never received a response of any kind from the DoJ, and several attempts to speak to someone at DoJ about the status of my inquiry resulted in my calls being transferred to the mailroom. Finally, I asked to speak with Attorney General Ashcroft's correspondence secretary. I twice left her a detailed message as per her voice mail instruction. Said voice mail promised to return my call, but I never received any call from anyone at the DoJ. As a result of my on-going efforts to clear my name as well as to learn as much as possible about the alleged use of my name in what people high in the intelligence community have labeled as treason, I wish to submit the addenda in Exhibit A. If the consent decree's Compliance Officer finds evidence of the aforereferenced sale to the PRC and my name is found in any documentation associated with that sale, I want to be so informed. I also understand that the names of several other people who had nothing to do with this alleged transaction were also included in the program's documentation. Further information is included in my sworn declaration in Exhibit B. I hope that you will take seriously my proposed addenda to the consent decree, and that, as a result, I might begin to find justice in a system that to date has proven to be anything but just. Respectfully submitted, Neil F. Keehn PROPOSED ADDENDA TO THE FINAL JUDGMENT
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