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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

MEDICAL MUTUAL OF OHIO,

                  Defendant.


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Civil Action
No. 1:98-CV-2172


STIPULATION FOR ENTRY OF FINAL JUDGMENT

It is stipulated by and between the undersigned parties, by their respective attorneys, that:

1. This Court has jurisdiction over the subject matter of this action and over both of the parties, and venue of this action is proper in the Northern District of Ohio.

2. The parties consent that a Final Judgment in the form attached may be filed and entered by the Court, upon the motion of either party or upon the Court's own action, at any time after compliance with the requirements of the Antitrust Procedures and Penalties Act (15 U.S.C. § 16), and without further notice to any party or other proceedings, provided that Plaintiff has not withdrawn its consent, which it may do at any time before the entry of the proposed Final Judgment by serving notice thereof on Defendant and by filing that notice with the Court.

3. If Plaintiff withdraws its consent, or if the proposed Final Judgment is not entered pursuant to the terms of this Stipulation, this Stipulation shall be of no effect whatsoever, and the making of this Stipulation shall be without prejudice to either party in this or in any other proceeding.

4. Defendant agrees to be bound by the provisions of the proposed Final Judgment pending its approval by the Court.

DATED: September 23, 1998

FOR PLAINTIFF:

_______________/s/________________
Joel I. Klein
Assistant Attorney General

_______________/s/________________
Donna E.Patterson
Deputy Assistant Attorney General

_______________/s/________________
Rebecca P. Dick
Director of Civil Non-Merger
Enforcement

_______________/s/________________
Gail Kursh
Chief, Health Care Task Force

_______________/s/________________
Paul J. O'Donnell
Jean Lin
Andre Barlow
Frederick Young
Attorneys
Antitrust Division
Department of Justice
325 7th Street, N.W.
Washington, D.C. 20530
(202)616-5933

_______________/s/________________
Emily M. Sweeney
United States Attorney
Northern District of Ohio
1800 Bank One Center
600 Superior Ave., E.
Cleveland, Ohio 44114-2600
(216) 622-3600


FOR DEFENDANT:

_______________/s/________________
Wayne C. Dabb (OO25700)
Gerald A. Connell
Baker & Hostetler, LLP
3200 National City Center
1900 East Ninth Street
Cleveland, OH 44114-3485
(216)621-0200