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' SECOND AMENDED NOTICE OF DEPOSITIONS

TO:	David A. Ettinger, Esq. Howard B. Iwrey, Esq. Honigman Miller Schwartz and Cohn 2290 First National Building Detroit, Michigan 48226-3583
	James D. Hodges, Esq. Shuttleworth & Ingersoll, P.C. Firstar Bank Building P.O. Box 2107 Cedar Rapids, Iowa 52406-22107

The United States notifies the defendants, pursuant to Fed. R. Civ. P. 30(b), that it will take depositions upon oral examination by stenographic means and videotape of the persons listed below commencing at the times and dates indicated. In this Second Amended Notice, the changes to the previous notice are indicated in italics. Barry Harris' deposition will take place at the United States Department of Justice, Antitrust Division, 555 Fourth Street, N.W., Room 9901, Washington, D.C. Duncan Gallagher's deposition will take place at the United States Attorney's Office, 234 U.S. Courthouse, 110 South 4th Street, Minneapolis, MN 55401. Roger Tracy's deposition will take place at the U.S. Attorney's Office, 425 2nd Street S.E., Ground Transportation Center, Suite 950, Cedar Rapids, Iowa. The remaining witnesses will be deposed at the Cycare Plaza Building, 740 Cycare Plaza, Dubuque, Iowa.

The dates and times of each deposition are noted below. If necessary, each deposition will be continued from day to day or be adjourned until completed.

Deponent	Date	Time
Mr. Lynn B. Fuller Dubuque Bank & Trust 1398 Central Dubuque, Iowa 52004-0778 (planned DRHS board member)	August 19, 1994	8:30 a.m.
Mr. Steven P. Sesterhenn Cycare Systems, Inc. One Cycare Plaza, Ste. 500 Dubuque, Iowa 52001	August 19, 1994	1:00 p.m.
Barry Harris, Ph.D. Economists, Inc. 12323 20th St., N.W. Ste. 600 Washington, D.C. 20036	August 31, 1994	8:30 a.m.
Mr. Roger Tracy University of Iowa College of Medicine Room 287 ML Iowa City, Iowa 52242-1181	August 22, 1994	8:30 a.m.
Mr. Duncan Gallagher KPMG Peat Marwick 4200 Norwest Center Minneapolis, MN 55402-3700	August 25, 1994	9:00 a.m.
R. W. Lengeling, M.D. Dubuque Internal Medicine, P.C. 1515 Delhi Street Dubuque, Iowa 52001	August 23, 1994	8:30 a.m.
Keith A. Shaw, M.D. The Finley Hospital 350 North Grandview Avenue Dubuque, Iowa 52001	August 23, 1994	1:00 p.m.
Rule 30(b)(6) Deposition Mercy Health Services	August 17, 1994	8:30 a.m.

Subject Matters:

• Money transfers and/or capital redistributions between Mercy Health Center and any of its parents or affiliates since January 1, 1989.
• Defendants' statement in "An Analysis of the Formation of Dubuque Regional Health System" that "[A]ll purchasers, including Deere, are likely to have benefited significantly from the Ottumwa merger."
• The preparation and dissemination of promotional materials regarding DRHS.
• The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

Rule 30(b)(6) Deposition Finley Tri-States Health Group, Inc.

August 15, 1994

8:30 a.m.

Subject Matters:

• Defendants' statement in "An Analysis of the Formation of Dubuque Regional Health System" that "[A]ll purchasers, including Deere, are likely to have benefited significantly from the Ottumwa merger."
• The preparation and dissemination of promotional materials regarding DRHS.
• The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

Rule 30(b)(6) Deposition

The Rule 30(b)(6) deposition notice for Peat Marwick has been withdrawn.

DATED: August 11, 1994

_______________/s/________________ Mary Beth McGee Eugene D. Cohen Jessica N. Cohen U.S. Department of Justice Antitrust Division 555 4th Street, N.W., Room 9421 Washington, D.C. 20001 Tel: (202) 307-1027 Fax: (202) 514-1517 Attorneys for the United States