In The United States District Court

For The District of Columbia

[FILED 9/20/95]

)
United States of America, )
)
)
Plaintiff, )
)
v. ) Civil Action No.:95 1804
)
)
National Automobile Dealers )
Association, )
)
)
Defendant. )
)

STIPULATION

It is stipulated by and between the undersigned parties, by their respective attorneys, that:

1. The Court has jurisdiction over the subject matter of this action and over each of the

parties hereto, and venue of this action is proper in the District of Columbia;

2. The parties to this Stipulation consent that a Final Judgment in the form attached may be

filed and entered by the Court, upon any party's or the Court's own motion, at any time after

compliance with the requirements of the Antitrust Procedures and Penalties Act (15 U.S.C. § 16),

without further notice to any party or other proceedings, provided that plaintiff has not withdrawn

its consent, which it may do at any time before entry of the proposed Final Judgment by serving

notice on the defendant and by filing that notice with the Court.

3. Defendant agrees to be bound by the provisions of the proposed Final Judgment pending

its approval by the Court. If plaintiff withdraws its consent or the proposed Final Judgment is not

entered pursuant to this Stipulation, this Stipulation shall be of no effect whatever and its making

shall be without prejudice to any party in this or any other proceedings.

DATED:

FOR THE PLAINTIFF THE UNITED STATES OF AMERICA:

/S/ /S/
Anne K. Bingaman Robert J. Zastrow
Assistant Attorney General Assistant Chief

/S/ /S/
Joel I. Klein Minaksi Bhatt
Deputy Assistant Attorney General

/S/ /S/
Rebecca P. Dick Susan L. Edelheit
Deputy Director of Operations DC Bar # 250720

/S/ /S/
Mary Jean Moltenbrey Theodore R. Bolema
Chief, Civil Task Force II
Attorneys
Civil Task Force II
Antitrust Division
U.S. Department of Justice
325 7th Street, NW
Washington, D.C. 20530

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FOR THE DEFENDANT THE NATIONAL AUTOMOBILE DEALERS ASSOCIATION:

/S/__________________________
Frank R. McCarthy
Executive Vice President
National Automobile Dealers Association
8400 Westpark Drive
McLean, VA 22102

/S/__________________________
Glenn A. Mitchell
Counsel for the National
Automobile Dealers Association
Stein, Mitchell & Mezines
1100 Connecticut Avenue, N.W.
Washington, D.C. 20035

/S/__________________________
Arthur L. Herold
Counsel for the National
Automobile Dealers Association
Webster, Chamberlain & Bean
1747 Pennsylvania Avenue, N.W.
Washington, D.C. 20006

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