United States' Second Amended Notice of Depositions

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF IOWA
EASTERN DIVISION

TO:	David A. Ettinger, Esq. Howard B. Iwrey, Esq. Honigman Miller Schwartz and Cohn 2290 First National Building Detroit, Michigan 48226-3583
	James D. Hodges, Esq. Shuttleworth & Ingersoll, P.C. Firstar Bank Building P.O. Box 2107 Cedar Rapids, Iowa 52406-22107

The United States notifies the defendants, pursuant to Fed. R. Civ. P. 30(b), that it will take depositions upon oral examination by stenographic means and videotape of the persons listed below commencing at the times and dates indicated. In this Second Amended Notice, the changes to the previous notice are indicated in italics. Barry Harris' deposition will take place at the United States Department of Justice, Antitrust Division, 555 Fourth Street, N.W., Room 9901, Washington, D.C. Duncan Gallagher's deposition will take place at the United States Attorney's Office, 234 U.S. Courthouse, 110 South 4th Street, Minneapolis, MN 55401. Roger Tracy's deposition will take place at the U.S. Attorney's Office, 425 2nd Street S.E., Ground Transportation Center, Suite 950, Cedar Rapids, Iowa. The remaining witnesses will be deposed at the Cycare Plaza Building, 740 Cycare Plaza, Dubuque, Iowa.

The dates and times of each deposition are noted below. If necessary, each deposition will be continued from day to day or be adjourned until completed.

Subject Matters:

• Money transfers and/or capital redistributions between Mercy Health Center and any of its parents or affiliates since January 1, 1989.
• Defendants' statement in "An Analysis of the Formation of Dubuque Regional Health System" that "[A]ll purchasers, including Deere, are likely to have benefited significantly from the Ottumwa merger."
• The preparation and dissemination of promotional materials regarding DRHS.
• The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

Subject Matters:

• Defendants' statement in "An Analysis of the Formation of Dubuque Regional Health System" that "[A]ll purchasers, including Deere, are likely to have benefited significantly from the Ottumwa merger."
• The preparation and dissemination of promotional materials regarding DRHS.
• The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

Rule 30(b)(6) Deposition

The Rule 30(b)(6) deposition notice for Peat Marwick has been withdrawn.