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



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

MERCY HEALTH SERVICES and
FINLEY TRI-STATES HEALTH
GROUP, INC.

                  Defendants.


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CIVIL ACTION NO. C 94-1023

HON. MICHAEL MELLOY



SCHEDULING STIPULATION: WITNESS DISCLOSURE

Defendants Mercy Health Services and Finley Tri-States Health Group, Inc. and plaintiff United States of America hereby stipulate to the following schedule regarding disclosure of final fact-witness lists and testifying experts and their materials.

Monday, August 8
  • Government will identify its testifying economics expert.
  • Defendants will identify their testifying efficiencies expert.

Monday, August 15
  • Both sides will exchange final fact-witness lists.
  • Government will produce its testifying economics expert's report.
  • Defendants will identify their remaining testifying experts.
  • Defendants will produces their efficiency expert's report.
  • Government will identify its rebuttal efficiencies expert.
  • Defendants' testifying efficiency expert and Government's testifying economics expert will be available for depositions from August 15 until the end of the discovery period.

Friday, August 19
  • Government will identify all testifying rebuttal expert witnesses other than its rebuttal efficiencies expert.

Monday, August 22
  • Defendants will produce all reports for its testifying experts other than its efficiencies expert.
  • Government will produce its efficiencies rebuttal expert's report.
  • Defendants' remaining testifying experts will be available for depositions from August 22 until the end of the discovery period.

Thursday, Aug 25
  • Government will produce reports for all rebuttal experts other than the Government's efficiencies expert. These witnesses will be available for depositions from August 25 until the end of the discovery period.
This order does not effect the parties' obligations under the Scheduling Order entered by the Court on June 24 or under the Federal Rules of Civil Procedure, including the parties' obligations to answer interrrogatories. By stipulating to this order, the parties do not waive any rights to object to witnesses on any grounds.

COUNSEL FOR PLAINTIFF
UNITED STATES OF AMERICA


_______________________________
Jessica N. Cohen
555 Fourth Street, N.W.
Room 9901
Washington, D.C. 20001
(202) 307-1027


Dated: ______________________, 1994.
COUNSEL FOR DEFENDANTS
MERCY HEALTH SERVICES and
FINLEY TRI-STATES HEALTH
GROUP, INC.


_______________________________
David A. Ettinger (P26537)
Howard B. Iwrey (P39635)
Honigman Miller Schwartz and Cohn
2290 First National Building
Detroit, Michigan 48226
(313) 256-7951