United States' Fourth Response to Defendants' First Interrogatires

The United States makes the following supplemental response to Defendants' Interrogatory No. 8.

Interrogatory 8:

Identify each person who will or may testify as a non-expert witness in this cause, and, with respect to each person, describe in detail: (a) the general subject matter on which such witness is expected to testify.

Answer:

The United States expects to call the following individuals to testify at trial (three of whom were previously indicated as "may call" witnesses in plaintiff's Response of June 29):

Witness Name	Subject Matter
Schemmel, Scott Paul, M.D. Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9161	Product market, geographic market and competitive effects.
Bishop, Thomas Chief Operating Officer Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9950	Product market, geographic market, competitive effects and managed healthcare.
Thomson, James K. Vice-President of Operations John Deere Health Care Represented by William Zessar Vice President/Gen. Counsel John Deere Health Care 1515 Fifth Ave., Ste. 200 Moline, IL 61265 (309) 765-1177	Product market, geographic market, competitive effects and managed healthcare.
Van Bell, Richard J. President John Deere Health Care Represented by William Zessar Vice President/Gen. Counsel John Deere Health Care 1515 Fifth Ave., Ste. 200 Moline, IL 61265 (309) 765-1177	Product market, geographic market, competitive effects and managed healthcare.

The United States may also call the following individuals to testify at trial (one of whom was previously indicated in plaintiff's June 29 response):

Witness Name	Subject Matter
Cremer, Lawrence E. Medical Associates, HMO One Cycare Plaza, Ste. 230 Dubuque, IA 52001 (319) 556-8070	Product market, geographic market, competitive effects and managed healthcare.
Runde, Mark, M.D. Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9890	Product market, geographic market, competitive effects.
Clark, Christopher, M.D. Medical Associates Clinic 100 Langworthy Dubuque, IA 52001 (319) 589-9821	Product market, geographic market, competitive effects.

At present, no final decision has been made about which witnesses the United States will call.

Dated: July 15, 1994

I, Mary Beth McGee, declare:

1. I am an attorney with the United States Department of Justice, Antitrust Division.

2. I verify that authorized employees and counsel for the United States assembled the facts stated herein; and that the facts herein are true and correct to the best of my knowledge, information, and belief.

3. I declare under penalty of perjury that the foregoing is true and correct.

Executed in Washington, D.C. on ________________, 1994.