Notice to the Court Regarding the United States’ Motion to Require UPM-Kymmene, Oyj to Make Available in the United States Responsive Documents and One Deponent Located in Finland

NOTICE TO THE COURT REGARDING THE UNITED STATES' MOTION TO REQUIRE UPM-KYMMENE, OYJ TO MAKE AVAILABLE IN THE UNITED STATES RESPONSIVE DOCUMENTS AND ONE DEPONENT LOCATED IN FINLAND

The United States originally provided the Court notice of its Motion to Require UPM-Kymmene Oyj to Make Available in the United States Responsive Documents and One Deponent Located in Finland, requesting that it be presented before the Court on Tuesday, May 13, 2003.

The United States hereby notifies the Court that on May 11, 2003, defendant UPM-Kymmene Oyj ("UPM") agreed to make its President and Chief Executive Officer, Juha Niemela, available in Washington, D.C., on May 19, 2003, for a deposition originally noticed for May 16, 2003, while no longer insisting on unrelated conditions that plaintiff considered unacceptable. This agreement renders moot the portion of plaintiff's above-referenced motion that requested the Court to order UPM to make Mr. Niemela available for a deposition. A revised proposed order is attached to this notice.

The United States also notifies the Court that with UPM's consent, it has re-scheduled presentation of the above-referenced motion before the Court to Thursday, May 15, at 10:15 am, or as soon thereafter as counsel may be heard, to discuss the remaining issue pertaining to UPM's refusal to produce responsive documents from Finland.

Dated: May 12, 2003

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

ORDER REQUIRING UPM-KYMMENE OYJ TO MAKE AVAILABLE IN THE UNITED STATES RESPONSIVE DOCUMENTS

For good cause shown, defendant UPM-Kymmene, Oyj ("UPM") is ORDERED to properly respond to document requests calling for documents located in Finland.

Dated: May ______, 2003

CERTIFICATE OF SERVICE

I hereby certify that copies of the foregoing Notice to the Court Regarding the United States' Motion to Require UPM-Kymmene Oyj to Make Available in the United States Responsive Documents and One Deponent Located in Finland were served by facsimile and first class mail upon each of the parties listed below:

Christopher M. Curran
White & Case LLP
601 Thirteenth Street, N.W., Suite 600 South
Washington, D.C. 20005-3807
Telephone: (202) 626-3600
Facsimile: (202) 639-9355

Alan S. Madans
Rothschild, Barry & Meyers
55 West Monroe Street, Suite 3900
Chicago, IL 60603-5012
Telephone: (312) 372-2345
Facsimile: (312) 372-2350
      Counsel for defendants UPM-Kymmene Oyj and Raflatac, Inc.

John D. French
Faegre & Benson LLP
2200 Wells Fargo Center
90 South Seventh Street
Minneapolis, MN, 55402-3901
Telephone: (612) 766-7000
Facsimile: (612) 766-1600

Thomas A. Doyle
Baker & McKenzie
One Prudential Plaza
130 East Randolph Drive
Chicago, IL 60601
Telephone: (312) 861-8866
      Counsel for defendants Bemis Company Inc. and Morgan Adhesives Company