Exhibit 10.6


 


	
   

  	
  [SEAL]

  
	
   

  	
  RECEIVED

  
	
   

  	
   

  
	
   

  	
  DEC 22 AM 9:38

  
	
   

  	
   

  
	
   

  	
  RICHARD W. WEEKING

  
	
   

  	
  CLERK, U.S. DISTRICT
  COURT

  
	
   

  	
  NORTHERN DISTRICT OF
  CALIFORNIA

  



 


BILL LOCKYER


Attorney General of the State of California


RICHARD M. FRANK


Chief Deputy Attorney General


THOMAS GREENE


Chief Assistant Attorney General


KATHLEEN E. FOOTE


Senior Assistant Attorney General


ADAM MILLER, State Bar No.168254


Deputy Attorney General


455 Golden Gate Avenue, Suite 11000


San Francisco, CA 94102-7004


Telephone: (415) 703-5551


Fax: (415) 703-5480


Email:
Adam.Miller@doj.ca.gov


 


Attorneys for the State of California


 


IN THE
UNITED STATES DISTRICT COURT



FOR THE NORTHERN DISTRICT OF CALIFORNIA


 


	
  STATE OF CALIFORNIA,

  	
   

  	
  CASE NO. 

  
	
   

  	
   

  	
   

  
	
  Plaintiff,

  	
   

  	
  STIPULATION
  FOR ENTRY OF

  FINAL JUDGMENT

  
	
  v.

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
  MARQUEE HOLDINGS, INC.,

  	
   

  	
   

  
	
  a Delaware corporation,

  	
   

  	
   

  
	
  d/b/a AMC ENTERTAINMENT INC.,

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
  and

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
  LCE HOLDINGS, INC.,

  a Delaware corporation,

  d/b/a LOEWS CINEPLEX

  ENTERTAINMENT CORPORATION,

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
  Defendants.

  	
   

  	
   

  



 


STIPULATION FOR ENTRY OF FINAL
JUDGMENT


 


It is stipulated
by and between the undersigned parties, through 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 United States
District Court for the Northern District of California.


 


STIPULATION FOR ENTRY OF FINAL JUDGMENT


 


1





















 


2.             The parties consent that a Final
Judgment in the form hereto attached may be filed and entered by the Court
without further notice to any party or other proceedings, provided that the plaintiff
has not withdrawn its consent, which it may do at any time before the entry of
the proposed Final Judgment by serving notice thereof on the defendants and by
filing notice with the Court.


 


3.             The defendants shall abide by and
comply with the provisions of the proposed Final Judgment pending entry of the
Final Judgment, or until expiration of time for all appeals of any court ruling
declining the entry of the proposed Final Judgment, and shall, from the date of
the filing of this Stipulation, comply with all the terms and provisions
thereof as though the same were in full force and effect as an order of the
Court.


 


4.             This Stipulation shall apply with
equal force and effect to any amended proposed Final Judgment agreed upon in
writing by the parties and submitted to the Court.


 


5.             In the event the plaintiff
withdraws its consent or if the proposed Final Judgment is not entered pursuant
to this Stipulation, this Stipulation shall have no effect whatever and the making
of this Stipulation shall be without prejudice to any party in this or any
other proceeding.


 


6.             The defendants represent that the
required actions set forth in the
proposed Final Judgment can and will be implemented and followed and that the
defendants will later raise no claim of hardship or difficulty as grounds for
asking the Court to modify any of the provisions contained therein.


 


2





















 


	
   

  	
   

  	
  Respectfully
  submitted,

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  FOR
  THE STATE OF CALIFORNIA:

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  BILL
  LOCKYER

  
	
   

  	
   

  	
  Attorney
  General of the State of California

  
	
   

  	
   

  	
  RICHARD
  M. FRANK

  
	
   

  	
   

  	
  Chief
  Deputy Attorney General

  
	
   

  	
   

  	
  THOMAS
  GREENE

  
	
   

  	
   

  	
  Chief
  Assistant Attorney General

  
	
   

  	
   

  	
  KATHLEEN
  E. FOOTE

  
	
   

  	
   

  	
  Senior
  Assistant Attorney General

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  /s/ Adam Miller

  
	
   

  	
   

  	
  ADAM
  MILLER

  
	
   

  	
   

  	
  Deputy
  Attorney General

  
	
   

  	
   

  	
  455
  Golden Gate Avenue, Suite 11000

  
	
   

  	
   

  	
  San
  Francisco, CA 94102-7004

  
	
   

  	
   

  	
  Telephone:
  

  	
  (415)
  703-5551

  
	
   

  	
   

  	
  Fax:
  

  	
  (415)
  703-5480

  
	
   

  	
   

  	
  Attorneys
  for the Plaintiff, State of California

  
	
   

  	
   

  	
   

  
	
  Dated:

  	
  12/19/05

  	
   

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  FOR
  MARQUEE HOLDINGS INC.:

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  /s/ Ilene Knable Gotts

  
	
   

  	
   

  	
  ILENE
  KNABLE GOTTS

  
	
   

  	
   

  	
  DAMIAN
  G. DIDDEN

  
	
   

  	
   

  	
  Wachtell,
  Lipton, Rosen & Katz

  
	
   

  	
   

  	
  51
  West 52nd Street

  
	
   

  	
   

  	
  New
  York, New York 10019

  
	
   

  	
   

  	
  Telephone:
  

  	
  (212)
  403-1247

  
	
   

  	
   

  	
  Fax:  

  	
  (212)
  403-2247

  
	
   

  	
   

  	
  Attorneys
  for Marquee Holdings Inc.

  
	
   

  	
   

  	
   

  
	
  Dated:

  	
  Dec 15, 2005

  	
   

  	
   

  	
   

  



 


3





















 


	
   

  	
   

  	
  FOR
  LCE HOLDINGS, INC.:

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  /s/ Deborah L. Feinstein

  	
   

  
	
   

  	
   

  	
  DEBORAH
  L. FEINSTEIN

  
	
   

  	
   

  	
  Arnold &
  Porter LLP

  
	
   

  	
   

  	
  555
  12th Street, NW

  
	
   

  	
   

  	
  Washington,
  DC 20004

  
	
   

  	
   

  	
  Telephone:
  

  	
  (202)
  942-5015

  
	
   

  	
   

  	
  Fax:

  	
  (202)
  942-5999

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  JENNIFER
  L. CUMMINGS (Cal. Bar # 208115)

  
	
   

  	
   

  	
  Arnold &
  Porter LLP

  
	
   

  	
   

  	
  90
  New Montgomery Street

  
	
   

  	
   

  	
  Suite 600

  
	
   

  	
   

  	
  San
  Francisco, CA 94105

  
	
   

  	
   

  	
  Telephone:
  

  	
  (415)
  356-3004

  
	
   

  	
   

  	
  Fax:
  

  	
  (415)
  356-3099

  
	
   

  	
   

  	
   

  
	
   

  	
   

  	
  Attorneys
  for LCE Holdings, Inc.

  
	
   

  	
   

  	
   

  
	
  Dated:

  	
   

  	
   

  	
   

  	
   

  
							



 


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