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FILED
JUL 21
2008
NANCY MAYER WHITTINGTON, CLERK
U.S. DISTRICT COURT
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
v.
SAS CARGO GROUP A/S,
Defendant.
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Criminal No. 08-cr-00182-JDB
Filed: July 21, 2008
Violation: 15 U.S.C § 1
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PLEA AGREEMENT
The United States of America and SAS Cargo Group A/S, ("defendant"),
a corporation organized and existing under the laws of Denmark,
hereby enter into the following Plea Agreement pursuant to Rule 11(c)(1)(C)
of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."):
RIGHTS OF DEFENDANT
- The defendant understands its rights:
- to be represented by an attorney;
- to be charged by Indictment;
- as a corporation organized and existing under the laws of Denmark,
to decline to accept service of the Summons in this case, and
to contest venue and the jurisdiction of the United States to
prosecute this case against it in the United States District Court
for the District of Columbia;
- to plead not guilty to any criminal charge brought against it;
- to have a trial by jury, at which it would be presumed not guilty
of the charge and the United States would have to prove every
essential element of the charged offense beyond a reasonable doubt
for it to be found guilty;
- to confront and cross-examine witnesses against it and to subpoena
witnesses in its defense at trial;
- to appeal its conviction if it is found guilty; and
- to appeal the imposition of sentence against it.
AGREEMENT TO PLEAD GUILTY AND WAIVE CERTAIN RIGHTS
- The defendant knowingly and voluntarily waives the rights set out
in Paragraph 1(b)-(g) above, including all jurisdictional defenses
to the prosecution of this case, and agrees voluntarily to consent
to the jurisdiction of the United States to prosecute this case against
it in the United States District Court for the District of Columbia.
The defendant also knowingly and voluntarily waives the right to file
any appeal, any collateral attack, or any other writ or motion, including
but not limited to an appeal under 18 U.S.C. § 3742, that challenges
the sentence imposed by the Court if that sentence is consistent with
or below the recommended sentence in Paragraph 8 of this Plea Agreement,
regardless of how the sentence is determined by the Court. This agreement
does not affect the rights or obligations of the United States as
set forth in 18 U.S.C. § 3742(b)-(c). Pursuant to Fed. R. Crim.
P. 7(b), the defendant will waive indictment and plead guilty at arraignment
to a one-count Information to be filed in the United States District
Court for the District of Columbia. The Information will charge the
defendant with participating in a combination and conspiracy to suppress
and eliminate competition by fixing the cargo rates charged to customers
in the United States and elsewhere for international air shipments,
from in or about February 2002 until at least February 14, 2006, the
exact dates being unknown to the United States, in violation of the
Sherman Antitrust Act, 15 U.S.C. § 1.
- The defendant, pursuant to the terms of this Plea Agreement, will
plead guilty to the criminal charge described in Paragraph 2 above
and will make a factual admission of guilt to the Court in accordance
with Fed. R. Crim. P. 11, as set forth in Paragraph 4 below.
FACTUAL BASIS FOR OFFENSE CHARGED
- Had this case gone to trial, the United States would have presented
evidence sufficient to prove the following facts against the defendant:
- For purposes of this Plea Agreement, the "relevant period" is
that period from in or about February 2002 until at least February
14, 2006. During the relevant period for the cargo conspiracy,
the defendant was a corporation organized and existing under the
laws of Denmark. The defendant has its principal place of business
in Copenhagen, Denmark and employed more than 1000 individuals.
During the relevant period, the defendant provided international
air transportation services for cargo ("air cargo services") on
trans-Atlantic routes to and from the United States. For the purposes
of this Plea Agreement, "air cargo services" shall mean the shipment
by air transportation for any portion of transit of any good,
property, mail, product, container or item, such as heavy equipment,
perishable commodities, and consumer goods. For its air cargo
services, the defendant charged its customers a rate that consisted
of both a base rate and, at times during the relevant period,
various surcharges and fees, such as a fuel surcharge and a security
surcharge. The amount of the base rate charged by the defendant
could vary based on the type and weight of the shipment, the origin
and/or destination of the shipment, and the nature of the goods
or products being shipped. The base rate, surcharges, and fees
charged to customers by the defendant are collectively referred
to herein as the "cargo rate." During the relevant period, the
defendant's sales of air cargo services from the United States
totaled approximately $153.8 million.
- During the relevant period, the defendant, through officers
and employees of SAS Cargo Group A/S ("SAS Cargo"), including
high-level personnel of SAS Cargo, participated in a conspiracy
with one or more international air cargo carriers, the primary
purpose of which was to suppress and eliminate competition by
fixing one or more components of the cargo rates charged to customers
for certain U.S./trans-Atlantic air shipments, including shipments
to and from the United States. In furtherance of the conspiracy,
the defendant, through officers and employees of SAS Cargo, engaged
in discussions and attended meetings with representatives of one
or more air cargo carriers. During these discussions and meetings,
agreements were reached to fix one or more components of the cargo
rates to be charged to purchasers of certain U.S./trans-Atlantic
air cargo services.
- During the relevant period, air cargo shipments sold by one
or more of the conspirator carriers, and aircraft necessary to
transport the air cargo shipments, as well as payments for the
air cargo shipments, traveled in interstate and foreign trade
and commerce. Certain of the business activities of the defendant
and its co-conspirators in connection with the sale and provision
of air cargo services affected by this conspiracy were within
the flow of, and substantially affected, interstate and foreign
trade and commerce.
POSSIBLE MAXIMUM SENTENCE
- The defendant understands that the statutory maximum penalty which
may be imposed against it upon conviction for a violation of Section
One of the Sherman Antitrust Act is a fine in an amount equal to the
greatest of:
- $100 million (15 U.S.C. § 1);
- twice the gross pecuniary gain the conspirators derived from
the crime (18 U.S.C. § 3571(c) and (d)); or
- twice the gross pecuniary loss caused to the victims of the
crime by the conspirators (18 U.S.C. § 3571(c)
and (d)).
- In addition, the defendant understands that:
- pursuant to 18 U.S.C. § 3561(c)(1), the Court
may impose a term of probation of at least one year, but not more
than five years;
- pursuant to §8B1.1 of the United States Sentencing Guidelines
("U.S.S.G.," "Sentencing Guidelines," or "Guidelines") or 18 U.S.C.
§ 3563(b)(2) or 3663(a)(3), the Court may order it to pay
restitution to the victims of the offense; and
- pursuant to 18 U.S.C. § 3013(a)(2)(B), the Court is
required to order the defendant to pay a $400 special assessment
upon conviction for the charged crime.
SENTENCING GUIDELINES
7. The defendant understands that the Sentencing Guidelines are advisory,
not mandatory, but that the Court must consider the Guidelines in effect
on the day of sentencing, along with the other factors set forth in
18 U.S.C. § 3553(a), in determining and imposing sentence. The
defendant understands that the Guidelines determinations will be made
by the Court by a preponderance of the evidence standard. The defendant
understands that although the Court is not ultimately bound to impose
a sentence within the applicable Guidelines range, its sentence must
be reasonable based upon consideration of all relevant sentencing factors
set forth in 18 U.S.C. § 3553(a). Pursuant to U.S.S.G. §1B1.8,
the United States agrees that self-incriminating information that the
defendant provides to the United States pursuant to this Plea Agreement
will not be used to increase the volume of affected commerce attributable
to the defendant or in determining the defendant's applicable Guidelines
range, except to the extent provided in U.S.S.G. §1B1.8(b).
SENTENCING AGREEMENT
8. Pursuant to Fed. R. Crim. P. 11(c)(1)(C), the United States and
the defendant agree that the appropriate disposition of this case is,
and agree to recommend jointly that the Court impose, a sentence requiring
the defendant to pay to the United States a criminal fine of $52 million
payable in installments as set forth below with interest accruing under
18 U.S.C. § 3612(f)(1)-(2) ("the recommended sentence"). The parties
agree that there exists no aggravating or mitigating circumstance of
a kind, or to a degree, not adequately taken into consideration by the
U.S. Sentencing Commission in formulating the Sentencing Guidelines
justifying a departure pursuant to U.S.S.G. §5K2.0. The parties
agree not to seek or support any sentence outside of the Guidelines
range nor any Guidelines adjustment for any reason that is not set forth
in this Plea Agreement. The parties further agree that the recommended
sentence set forth in this Plea Agreement is reasonable.
Guidelines Analysis
- Pursuant to U.S.S.G. § 8C2.5, the defendant's culpability
score is 7. This number is calculated by starting with 5 points pursuant
to U.S.S.G. § 8C2.5 (a); adding 4 points because the organization
has 1000 or more employees and an individual within high-level personnel
of the organization participated in, condoned, or was willfully ignorant
of the offense, pursuant to U.S.S.G. § 8C2.5(b)(2)(A); and subtracting
2 points because the defendant fully cooperated in the investigation
and clearly demonstrated recognition and affirmative acceptance of
responsibility for its criminal conduct, pursuant to U.S.S.G. §
8C2.5(g)(2). Accordingly, the minimum multiplier to be applied to
the base fine is 1.4 and the maximum multiplier is 2.8, pursuant to
U.S.S.G § 8C2.6;
- The base fine is 20% of the volume of commerce, pursuant to U.S.S.G.
§ 2R1.1(d)(1) and §8C2.4(a) and (b). The parties agree that
the affected volume of commerce attributable to the defendant for
purposes of the Information is $153,788,738. The base fine for relevant
air cargo shipments from the United States is $30,757,748 (20% of
$153,788,738). Applying the multipliers of 1.4 and 2.8 to this amount,
the fine range for the relevant air cargo shipments from the United
States is $43,060,847 to $86,121,694.
- The volume of affected commerce calculation in paragraph 8(b) above
does not include commerce related to the defendant's cargo shipments
on trans-Atlantic routes into the United States. The defendant takes
the position that any agreements reached with competitors with respect
to cargo shipments on trans-Atlantic routes into the United States
should not be included in the defendant's volume of affected commerce
calculation pursuant to U.S.S.G. § 2R1.1(d)(1). The United States
disputes the defendant's position and contends that the defendant's
cargo shipments on trans-Atlantic routes into the United States during
the charged period violated the U.S. antitrust laws. Moreover, the
United States asserts that a Guidelines fine calculation that fails
to account for cargo shipments into the United States affected by
the charged cargo conspiracy would understate the seriousness of,
and the harm caused to U.S. victims by, the offense and would not
provide just punishment.
- The parties recognize the complexity of litigating the issues set
forth in Paragraph 8(c) and the resulting burden on judicial and party
resources, and agree that the appropriate resolution of this issue
is to impose a fine in the lower end of the Guidelines sentencing
range consistent with the early cooperation and substantial assistance
provided by the defendant in this matter. The parties agree that the
appropriate fine for the commerce affected by defendant's participation
in the charged conspiracy is $52 million payable as set forth in paragraph
8(e) below.
- The United States and the defendant agree to recommend, in the
interest of justice pursuant to 18 U.S.C. § 3572(d)(1) and U.S.S.G.
§8C3.2(b), that the fine be paid in the following installments:
within thirty (30) days of imposition of sentence -- $12 million (plus
any accrued interest); at the one-year anniversary of imposition of
sentence ("anniversary") -- $10 million (plus any accrued interest);
at the two-year anniversary -- $10 million (plus any accrued interest);
at the three-year anniversary -- $10 million (plus any accrued interest);
and at the four-year anniversary -- $10 million (plus any accrued
interest); provided, however, that the defendant shall have the option
at any time before the four-year anniversary of prepaying the remaining
balance (plus any accrued interest) then owing on the fine.
- The defendant understands that the Court will order it to pay a
$400 special assessment, pursuant to 18 U.S.C. § 3013(a)(2)(B),
in addition to any fine imposed.
- Based on the defendant's substantial assistance and improvements
to its corporate compliance program, the United States and the defendant
will jointly recommend that no term of probation be imposed, but the
parties understand that the Court's denial of this request will not
void this Plea Agreement.
- The United States and the defendant jointly submit that this Plea
Agreement, together with the record that will be created by the United
States and the defendant at the plea and sentencing hearings, and
the further disclosure described in Paragraph 9, will provide sufficient
information concerning the defendant, the crime charged in this case,
and the defendant's role in the crime to enable the meaningful exercise
of sentencing authority by the Court under 18 U.S.C. § 3553.
The United States and defendant agree to request jointly that the
Court accept the defendant's guilty plea and impose sentence on an
expedited schedule as early as the date of arraignment, based upon
the record provided by the defendant and the United States, under
the provisions of Fed. R. Crim. P. 32(c)(1)(A)(ii) and U.S.S.G. §6A1.1.
The Court's denial of the request to impose sentence on an expedited
schedule will not void this Plea Agreement.
9. Subject to the ongoing, full, and truthful cooperation of SAS,
as defined in Paragraph 12 of this Plea Agreement, and before sentencing
in the case, the United States will fully advise the Court and the Probation
Office of the fact, manner, and extent of SAS's cooperation and its
commitment to prospective cooperation with the United States' investigation
and prosecutions, all material facts relating to the defendant's involvement
in the charged offense, and all other relevant conduct.
10. The United States and the defendant understand that the Court
retains complete discretion to accept or reject the recommended sentence
provided for in Paragraph 8 of this Plea Agreement.
- If the Court does not accept the recommended sentence, the United
States and the defendant agree that this Plea Agreement, except for
Paragraph 10(b) below, shall be rendered void.
- If the Court does not accept the recommended sentence, the defendant
will be free to withdraw its guilty plea (Fed. R. Crim. P. 11(c)(5)
and (d)). If the defendant withdraws its plea of guilty, this Plea
Agreement, the guilty plea, and any statement made in the course of
any proceedings under Fed. R. Crim. P. 11 regarding the guilty plea
or this Plea Agreement or made in the course of plea discussions with
an attorney for the government shall not be admissible against the
defendant in any criminal or civil proceeding, except as otherwise
provided in Fed. R. Evid. 410. In addition, the defendant agrees that,
if it withdraws its guilty plea pursuant to this subparagraph of the
Plea Agreement, the statute of limitations period for any offense
referred to in Paragraph 14 of this Plea Agreement shall be tolled
for the period between the date of the signing of the Plea Agreement
and the date the defendant withdrew its guilty plea or for a period
of sixty (60) days after the date of the signing of the Plea Agreement,
whichever period is greater.
11. In light of pending civil class action lawsuits filed against
the defendant, which potentially provide for a recovery of a multiple
of actual damages, the United States agrees that it will not seek restitution
for the offense charged in the Information.
DEFENDANT'S COOPERATION
12. The defendant, its parent and their subsidiaries (collectively
"SAS") will cooperate fully and truthfully with the United States in
the prosecution of this case, the conduct of the current federal investigation
of violations of federal antitrust and related criminal laws involving
the sale of air cargo services, and any litigation or other proceedings
arising or resulting from such investigation to which the United States
is a party ("Federal Proceeding"). The ongoing, full, and truthful cooperation
of SAS shall include, but not be limited to:
- producing to the United States all non-privileged documents, information,
and other materials (with translations into English), wherever located,
in the possession, custody, or control of SAS, requested by the United
States in connection with any Federal Proceeding; and
- using its best efforts to secure the ongoing, full, and truthful
cooperation, as defined in Paragraph 13 of this Plea Agreement, of
the current and former directors, officers, and employees of SAS as
may be requested by the United States, but excluding Peter Grnlund,
Kenneth Marx, Jan Lillieborg, and Timothy Pfeil, including making
these persons available in the United States and at other mutually
agreed-upon locations, at the defendant's expense, for interviews
and the provision of testimony in grand jury, trial, and other judicial
proceedings in connection with any Federal Proceeding.
13. The ongoing, full, and truthful cooperation of each person described
in Paragraph 12(b) above will be subject to the procedures and protections
of this paragraph, and shall include, but not be limited to:
- producing in the United States and at other mutually agreed-upon
locations all non-privileged documents, including claimed personal
documents, and other materials, wherever located, requested by attorneys
and agents of the United States;
- making himself or herself available for interviews in the United
States and at other mutually agreed-upon locations, not at the expense
of the United States, upon the request of attorneys and agents of
the United States;
- responding fully and truthfully to all inquiries of the United States
in connection with any Federal Proceeding, without falsely implicating
any person or intentionally withholding any information, subject to
the penalties of making false statements (18 U.S.C. § 1001) and
obstruction of justice (18 U.S.C. § 1503, et seq.);
- otherwise voluntarily providing the United States with any non-privileged
material or information not requested in (a) - (c) of this paragraph
that he or she may have that is related to any Federal Proceeding;
- when called upon to do so by the United States in connection with
any Federal Proceeding, testifying in grand jury, trial, and other
judicial proceedings in the United States fully, truthfully, and under
oath, subject to the penalties of perjury (18 U.S.C. § 1621),
making false statements or declarations in grand jury or court proceedings
(18 U.S.C. § 1623), contempt (18 U.S.C. §§ 401-402),
and obstruction of justice (18 U.S.C. § 1503, et seq.);
and
- agreeing that, if the agreement not to prosecute him or her in this
Plea Agreement is rendered void under Paragraph 15(c), the statute
of limitations period for any Relevant Offense as defined in Paragraph
15(a) shall be tolled as to him or her for the period between the
date of the signing of this Plea Agreement and six (6) months after
the date that the United States gave notice of its intent to void
its obligations to that person under the Plea Agreement.
GOVERNMENT'S AGREEMENT
14. Upon acceptance of the guilty plea called for by this Plea Agreement
and the imposition of the recommended sentence, and subject to the cooperation
requirements of Paragraph 12 of this Plea Agreement, the United States
agrees that it will not bring further criminal charges against SAS for
any act or offense committed before the date of this Plea Agreement
that was undertaken in furtherance of an antitrust conspiracy involving
the sale of air cargo services. The nonprosecution terms of this paragraph
do not apply to civil matters of any kind, to any violation of the federal
tax or securities laws, or to any crime of violence.
15. The United States agrees to the following:
- Upon the Court's acceptance of the guilty plea called for by this
Plea Agreement and the imposition of the recommended sentence and
subject to the exceptions noted in Paragraph 15(c), the United
States will not bring criminal charges against any current or former
director, officer, or employee of SAS for any act or offense committed
before the date of this Plea Agreement and while that person was acting
as a director, officer, or employee of SAS that was undertaken in
furtherance of an antitrust conspiracy involving the sale of air cargo
services ("Relevant Offense"), except that the protections granted
in this paragraph shall not apply to Peter Grnlund, Kenneth Marx,
Jan Lillieborg, and Timothy Pfeil;
- Should the United States determine that any current or former director,
officer, or employee of SAS may have information relevant to any Federal
Proceeding, the United States may request that person's cooperation
under the terms of this Plea Agreement by written request delivered
to counsel for the individual (with a copy to the undersigned counsel
for the defendant) or, if the individual is not known by the United
States to be represented, to the undersigned counsel for the defendant;
- If any person requested to provide cooperation under Paragraph 15(b)
fails to comply with his or her obligations under Paragraph 13, then
the terms of this Plea Agreement as they pertain to that person, and
the agreement not to prosecute that person granted in this Plea Agreement,
shall be rendered void;
- Except as provided in Paragraph 15(e), information provided by a
person described in Paragraph 15(b) to the United States under the
terms of this Plea Agreement pertaining to any Relevant Offense, or
any information directly or indirectly derived from that information,
may not be used against that person in a criminal case, except in
a prosecution for perjury (18 U.S.C. § 1621), making a false
statement or declaration (18 U.S.C. §§ 1001, 1623),
or obstruction of justice (18 U.S.C. § 1503, et seq.);
- If any person who provides information to the United States under
this Plea Agreement fails to comply fully with his or her obligations
under Paragraph 13 of this Plea Agreement, the agreement in Paragraph
15(d) not to use that information or any information directly or indirectly
derived from it against that person in a criminal case shall be rendered
void;
- The nonprosecution terms of this paragraph do not apply to civil
matters of any kind, to any violation of the federal tax or securities
laws, or to any crime of violence; and
- Documents provided under Paragraphs 12(a) and 13(a) shall be deemed
responsive to outstanding grand jury subpoenas issued to SAS.
16. The United States agrees that when any person travels to the United
States for interviews, grand jury appearances, or court appearances
pursuant to this Plea Agreement, or for meetings with counsel in preparation
therefor, the United States will take no action, based upon any Relevant
Offense, to subject such person to arrest, detention, or service of
process, or to prevent such person from departing the United States.
This paragraph does not apply to an individual's commission of perjury
(18 U.S.C. § 1621), making false statements (18 U.S.C. §
1001), making false statements or declarations in grand jury or court
proceedings (18 U.S.C. § 1623), obstruction of justice (18
U.S.C. § 1503, et seq.), or contempt (18 U.S.C. §§
401-402) in connection with any testimony or information provided or
requested in any Federal Proceeding.
17. The defendant understands that SAS may be subject to administrative
action by federal or state agencies other than the United States Department
of Justice, Antitrust Division, based upon the conviction resulting
from this Plea Agreement, and that this Plea Agreement in no way controls
whatever action, if any, other agencies may take. However, the United
States agrees that, if requested, it will advise the appropriate officials
of any governmental agency considering such administrative action of
the fact, manner, and extent of the cooperation of SAS as a matter for
that agency to consider before determining what administrative action,
if any, to take.
REPRESENTATION BY COUNSEL
18. The defendant has been represented by counsel and is fully satisfied
that its attorneys have provided competent legal representation. The
defendant has thoroughly reviewed this Plea Agreement and acknowledges
that counsel has advised it of the nature of the charge, any possible
defenses to the charge, and the nature and range of possible sentences.
VOLUNTARY PLEA
19. The defendant's decision to enter into this Plea Agreement and
to tender a plea of guilty is freely and voluntarily made and is not
the result of force, threats, assurances, promises, or representations
other than the representations contained in this Plea Agreement. The
United States has made no promises or representations to the defendant
as to whether the Court will accept or reject the recommendations contained
within this Plea Agreement.
VIOLATION OF PLEA AGREEMENT
20. The defendant agrees that, should the United States determine
in good faith, during the period that any Federal Proceeding is pending,
that SAS has failed to provide full and truthful cooperation, as described
in Paragraph 12 of this Plea Agreement, or has otherwise violated any
provision of this Plea Agreement, the United States will notify counsel
for the defendant in writing by personal or overnight delivery or facsimile
transmission and may also notify counsel by telephone of its intention
to void any of its obligations under this Plea Agreement (except its
obligations under this paragraph), and SAS shall be subject to prosecution
for any federal crime of which the United States has knowledge including,
but not limited to, the substantive offense relating to the investigation
resulting in this Plea Agreement. The defendant agrees that, in the
event that the United States is released from its obligations under
this Plea Agreement and brings criminal charges against SAS for any
offense referred to in Paragraph 14 of this Plea Agreement, the statute
of limitations period for such offense shall be tolled for the period
between the date of the signing of this Plea Agreement and six (6) months
after the date the United States gave notice of its intent to void its
obligations under this Plea Agreement.
21. The defendant understands and agrees that in any further prosecution
of SAS resulting from the release of the United States from its obligations
under this Plea Agreement, because of SAS's violation of the Plea Agreement,
any documents, statements, information, testimony, or evidence provided
by SAS or its current or former directors, officers, or employees to
attorneys or agents of the United States, federal grand juries, or courts,
and any leads derived therefrom, may be used against SAS in any such
further prosecution. In addition, the defendant unconditionally waives
its right to challenge the use of such evidence in any such further
prosecution, notwithstanding the protections of Fed. R. Evid. 410.
ENTIRETY OF AGREEMENT
22. This Plea Agreement constitutes the entire agreement between the
United States and the defendant concerning the disposition of the criminal
charge in this case. This Plea Agreement cannot be modified except in
writing, signed by the United States and the defendant.
23. The undersigned is authorized to enter this Plea Agreement on
behalf of the defendant as evidenced by the Resolution of the Board
of Directors of the defendant attached to, and incorporated by reference
in, this Plea Agreement.
24. The undersigned attorneys for the United States have been authorized
by the Attorney General of the United States to enter this Plea Agreement
on behalf of the United States.
25. A facsimile signature shall be deemed an original signature for
the purpose of executing this Plea Agreement. Multiple signature pages
are authorized for the purpose of executing this Plea Agreement.
DATED:____June 26, 2008_____________ |
Respectfully submitted, |
BY:
By:
Its:
BY:
|
_______________/s/________________
SAS Cargo Group A/S
______/s/____________________
______/s/____________________
_______________/s/________________
Jeffrey Blumenfeld
Stephen M. Byers
Kent A. Gardiner
Crowell & Moring
1001 Pennsylvania Ave, NW
Washington, DC 20004
Tel: (202) 624-2919
Counsel for SAS Cargo Group A/S
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BY: |
_______________/s/________________
Mark R. Rosman, Assistant Chief
Brent Snyder, Trial Attorney
Kathryn M. Hellings, Trial Attorney
Elizabeth Aloi, Trial Attorney
U.S. Department of Justice
Antitrust Division
450 5th Street, NW
Suite 11300
Washington, D.C. 20530
Tel.: (202) 307-6694
Fax: (202) 514-6525 |
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