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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.,
               Defendant.


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Civil Action No. C94-1023

Hon. Michael J. Melloy

NOTICE OF DEPOSITIONS



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. With the exception of Barry Harris, the depositions will take place at the U.S. Attorney's Office, 425 2nd Street S.E., Ground Transportation Center, Suite 950, Cedar Rapids, Iowa, 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. 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 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.
Rule 30(b)(6) Deposition

Mercy Health Services

August 15,

19948:30 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 16, 1994 1 p.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
KPMG Peat Marwick4200 Norwest Center
90th S. Seventh Street
Minneapolis, MN 55402-3900
August 18, 1994 1 p.m.

Subject Matter:

The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

DATED: July 19, 1994

___________________________
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