This document is available in two formats: this web page (for browsing content), and PDF (comparable to original document formatting).  To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.

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.


|
|
|
|
|
|
|
|
|
|
|
|
|
|         

Civil Action No. C94-1023

Hon. Michael J. Melloy

Expedited Relief Requested
Oral Argument Requested

United States' Motion to
Compel Answers to Interrogatories

Pursuant to Fed. R. Civ. P. 37(a), the Government moves this Court to issue an order compelling defendants Mercy Health Services and Finley Tri-States Health Group, Inc. to serve upon the Government full and complete answers to Interrogatories 21(iii) and 31 of the United States' Second Request for Answers to Interrogatories and Interrogatory 1 of the United States' Third Request for Answers to Interrogatories (which consisted only of this one interrogatory). The Government requests expedited treatment of this motion because this case has been set on an expedited schedule. The complaint was filed on June 10 and trial is on September 12 (discovery ends on September 2).

The Government served Interrogatories 21(iii) and 31 upon the defendants on July 1. The Government served its Third Request for Answers to Interrogatories on the defendants on July 7. Defendants' answers to all three are woefully inadequate. Defendants refuse to answer Interrogatory 31. Their answers to Interrogatories 21(iii) and 1 are almost entirely deficient. For the reasons stated in the accompanying memorandum, the Court should issue an Order compelling the defendants to give full and complete answers.

The United States requests both expedited treatment under Local Rule 14(m) and oral argument of this Motion.



DATED: August 4, 1994 Respectfully submitted,




Stephen J. Rapp
United States Attorney

By:____________________________
Lawrence D. Kudej
Assistant United States Attorney
Northern District of Iowa
P.O. Box 74950
Cedar Rapids, Iowa 52407
Tel: (319) 363-0091
Fax: (319) 363-6110

___________________________
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