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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

__________________________________________

UNITED STATES OF AMERICA,
         Plaintiff,

                  v.

VISA U.S.A. INC.,
VISA INTERNATIONAL CORP., AND
MASTERCARD INTERNATIONAL
INCORPORATED,
         Defendant.
__________________________________________
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98 Civ. 7076 (BSJ)(THK)

NOTICE OF DEPOSITIONS


TO: COUNSEL FOR DEFENDANTS

PLEASE TAKE NOTICE that counsel for plaintiff United States of America will take the deposition upon oral examination of the persons listed below. The location, date and time for commencement of each deposition will be agreed among plaintiff, the witness and his counsel, unless otherwise indicated below. Without prejudice to the Government's right to take as long to complete each deposition as may be necessary, we note that our current expectation is that each listed deposition can be completed in a day. We will inform you in the future if that expectation changes. Moreover, we will inform you when we determine which, if any, depositions we intend to videotape.

 
DEPONENT LOCATION DATE TIME
John Bennett (former EVP at Visa International)

 To be agreed To be agreed  
Carol Cove Benson (former SVP of Visa International)

To be agreed To be agreed  
Patrick Boylan (member of Mastercard International Board of Directors)

 To be agreed To be agreed  
David Brooks (former SVP, Visa USA)

To be agreed To be agreed
Joseph Pino Francini (former EVP, Visa International)

 To be agreed To be agreed  
Richard Hartnack (MasterCard US Board member)

 To be agreed To be agreed  
Russ Hogg (former CEO of MasterCard International)

 To be agreed To be agreed  
William Jacobs (EVP, MasterCard)

To be agreed To be agreed  
Edmund Jensen (former CEO, Visa International)

To be agreed To be agreed  
Eugene Lockhart (former CEO, MasterCard International)

To be agreed To be agreed  
Bradford Morgan (former Visa USA employee)

 To be agreed To be agreed  
Flilip Pinhal of Banco Commericiale Portugese; Lisbon, Portugual Pasadena, CA
(where the witness
will be that day)

 Oct. 7, 1999 2:00 p.m.
John Reed (co-chairman of Citigroup)

To be agreed To be agreed  
Charles Russel (former CEO, Visa USA and Visa Int'l) To be agreed To be agreed  



You are invited to attend and participate in the examinations.


  _______________/s/________________
Melvin A. Schwarz (MS8604)
Special Counsel for Civil Enforcement
U.S. Department of Justice
Antitrust Division
325 7th Street, N.W., Room 300
Washington, DC 20530
(202) 305-3652

Dated: Washington, D.C.
September 15, 1999