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FOR THE DISTRICT OF KANSAS
FED.R.CIV.P. 30(B)(6)
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 Sabre, Inc. ("Sabre"). The deposition(s) will commence at 9:00 a.m. on August 31, 2000. If necessary, each deposition will be adjourned until completed. Sabre is requested to designate one or more 30(b)(6) witnesses who is(are) knowledgeable and prepared to testify fully on behalf of Sabre regarding the following topics: 1. The following documents as provided in Attachment A: "Decision Analysis Preliminary Results", labeled AALIT12200597 to AALIT12200607; "Integrating AA Planning: Pricing, Yield Management, Capacity Planning Report to Steering Committee", labeled AALIT02200125 to AALIT02200139; "AA Planning in a Competitive Environment: Integrating Pricing, Yield Management, and Capacity Planning Final Presentation", labeled AALIT02200041 to AALIT02200092; "A Vision of AA Strategy Development and Evaluation", labeled AALIT02200140 to AALIT02200148; "Proposal for Price Balance Statistic: First Step to Pricing Optimization", labeled AALIT22000110 to AALIT22000114; "AA Planning in a Competitive Environment: Integrating Pricing, Yield Management, and Capacity Planning", labeled AALIT22000234 to AALIT22000253; "Integrated Planning Model", labeled AALIT22000280 to AALIT22000304, including:
2. Whether each document listed in (1) and the document(s) produced in response to Attachment B hereto constitutes a business record of Sabre, as that term is used in Fed. R. Evid. 803(6), including:
3. The authenticity of each document listed in (1) and the authenticity of the
documents requested to be produced in Attachment B hereto.
Dated: August 21, 2000 Respectfully submitted COUNSEL FOR PLAINTIFF UNITED STATES _______________/s/________________
(1) "Decision Analysis Preliminary Results", labeled AALIT12200597 to AALIT12200607; (2) "Integrating AA Planning: Pricing, Yield Management, Capacity Planning Report to Steering Committee", labeled AALIT02200125 to AALIT02200139; (3) "AA Planning in a Competitive Environment: Integrating Pricing, Yield Management, and Capacity Planning Final Presentation", labeled AALIT02200041 to AALIT02200092; (4) "A Vision of AA Strategy Development and Evaluation", labeled AALIT02200140 to AALIT02200148; (5) "Proposal for Price Balance Statistic: First Step to Pricing Optimization", labeled AALIT22000110 to AALIT22000114; (6) "AA Planning in a Competitive Environment: Integrating Pricing, Yield Management, and Capacity Planning", labeled AALIT22000234 to AALIT22000253; (7) "Integrated Planning Model", labeled AALIT22000280 to AALIT22000304 |