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' FIFTH 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:

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

The United States may also call the following individuals to testify at trial:

Witness Name	Subject Matter
Cremer, Lawrence E. Medical Associates HMO One Cycare Plaza, Suite 230 Dubuque, IA 52001 (319) 556-8070	Product market, geographic market, competitive effects, and managed health care.
Runde, Mark M.D. Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9890	Product market, geographic market, competitive effects, and managed health care.
Clark, Christopher M.D. Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9890	Product market, geographic market, competitive effects, and managed health care.
Guetzko, Gary Vice President of Financing Mercy Health Center Mercy Drive Dubuque, IA 52001 (319) 589-6021	Product market, geographic market, competitive effects, managed health care, background of Finley & Mercy, and promotion of DRHS, as well as defendants' claimed efficiencies and transfers of money from Mercy Health Center to its parents or affiliates.
Sister Helen Huewe, O.S.f. President/CEO Mercy Health Center Mercy Drive Dubuque, IA 52001 (319) 589-8000	Product market, geographic market, competitive effects, managed health care, background of Finley and Mercy, and promotion of DRHS.
Kevin Rogols President/CEO The Finley Hospital 360 N. Grandview Ave. Dubuque, IA 52001 (319) 589-2413	Product market, geographic market, competitive effects, managed health care, background of Finley and Mercy, and promotion of DRHS.
Terry L. Steele Vice Pres./CFO The Finley Hospital 360 N. Grandview Ave. Dubuque, IA 52001 (319) 589-2373	Product market, geographic market, competitive effects, managed health care, background of Finley and Mercy, and promotion of DRHS, as well as defendants' claimed efficiencies.
Rod Tokheim Vice Pres. of Marketing &Planning The Finley Hospital 360 N. Grandview Ave. Dubuque, IA 52001 (319) 589-8056	Product market, geographic market, competitive effects, managed health care, background of Finley and Mercy, and promotion of DRHS.
David Shaller Administrative Director of Medical Staff & Community Relations The Finley Hospital 360 N. Grandview Ave. Dubuque, IA 52001 (319) 582-1881	Product market, geographic market, competitive effects, managed health care, background of Finley and Mercy, and promotion of DRHS.

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

Dated: August 2, 1994

_____________________________ Mary Beth McGee Eugene D. Cohen Jessica N. Cohen U.S. Department of Justice Antitrust Division 555 4th Street, N.W. Room 9901 Washington, D.C. 20001 Tel: (202) 307-1027 Fax: (202) 514-1517

I, Jessica N. Cohen, 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.

_______________________________ JESSICA N. COHEN