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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF IOWA
EASTERN DIVISION



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

MERCY HEALTH SERVICES and
FINLEY TRI-STATES HEALTH
GROUP, INC.,

                  Defendants.


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Civil Action No. C94-1023

Hon. Michael J. Melloy

UNITED STATES' FOURTH
RESPONSE TO DEFENDANTS'
FIRST INTERROGATORIES



UNITED STATES' FOURTH RESPONSE TO
DEFENDANTS' FIRST INTERROGATORIES

The United States makes the following supplemental response to Defendants' Interrogatory No. 8.

Interrogatory 8:

Identify each person who will or may testify as a non-expert witness in this cause, and, with respect to each person, describe in detail: (a) the general subject matter on which such witness is expected to testify.

Answer:

The United States expects to call the following individuals to testify at trial (three of whom were previously indicated as "may call" witnesses in plaintiff's Response of June 29):

    Witness Name

    Subject Matter
    Schemmel, Scott Paul, M.D.
    Medical Associates Clinic
    100 Langworthy
    Dubuque, IA 52001
    (319) 589-9161

    Product market, geographic market and competitive effects.
    Bishop, Thomas
    Chief Operating Officer
    Medical Associates Clinic
    100 Langworthy
    Dubuque, IA 52001
    (319) 589-9950

    Product market, geographic market, competitive effects and managed healthcare.
    Thomson, James K.
    Vice-President of Operations
    John Deere Health Care
    Represented by William Zessar
    Vice President/Gen. Counsel
    John Deere Health Care
    1515 Fifth Ave., Ste. 200
    Moline, IL 61265
    (309) 765-1177

    Product market, geographic market, competitive effects and managed healthcare.
    Van Bell, Richard J.
    President
    John Deere Health Care
    Represented by William Zessar
    Vice President/Gen. Counsel
    John Deere Health Care
    1515 Fifth Ave., Ste. 200
    Moline, IL 61265
    (309) 765-1177

    Product market, geographic market, competitive effects and managed healthcare.

The United States may also call the following individuals to testify at trial (one of whom was previously indicated in plaintiff's June 29 response):

    Witness Name

    Subject Matter
    Cremer, Lawrence E.
    Medical Associates, HMO
    One Cycare Plaza, Ste. 230
    Dubuque, IA 52001
    (319) 556-8070

    Product market, geographic market, competitive effects and managed healthcare.
    Runde, Mark, M.D.
    Medical Associates Clinic
    100 Langworthy
    Dubuque, IA 52001
    (319) 589-9890

    Product market, geographic market, competitive effects.
    Clark, Christopher, M.D.
    Medical Associates Clinic
    100 Langworthy
    Dubuque, IA 52001
    (319) 589-9821

    Product market, geographic market, competitive effects.

At present, no final decision has been made about which witnesses the United States will call.


Dated: July 15, 1994

_______________/s/________________
Mary Beth McGee
Eugene D. Cohen
Richard S. Martin
Jesse M. Caplan
Ann Lea Harding

U.S. Department of Justice
Antitrust Division
555 4th Street, N.W. Room 9421
Washington, D.C. 20001
Tel: (202) 307-1037
Fax: (202) 514-1517


VERIFICATION

I, Mary Beth McGee, declare:

1. I am an attorney with the United States Department of Justice, Antitrust Division.

2. I verify that authorized employees and counsel for the United States assembled the facts stated herein; and that the facts herein are true and correct to the best of my knowledge, information, and belief.

3. I declare under penalty of perjury that the foregoing is true and correct.


Executed in Washington, D.C. on ________________, 1994.




_______________________________
MARY BETH MCGEE