UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF IOWA

EASTERN DIVISION

UNITED STATES OF AMERICA,	)

)

Plaintiff,	)	Civil Action No. C94-1023

)

vs.	)	Hon. Michael J. Melloy

)

MERCY HEALTH SERVICES and	)	NOTICE OF DEPOSITIONS

FINLEY TRI-STATES HEALTH	)

GROUP, INC.,	)

)

Defendants.	)

NOTICE OF DEPOSITIONS

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. With the exception of Barry Harris, the depositions will take place at the U.S. Attorney's Office, 425 2nd Street S.E., Ground Transportation Center, Suite 950, Cedar Rapids, Iowa, 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. If necessary, each deposition will be continued from day to day or be adjourned until completed.

Deponent	Date	Time

Mr. Lynn B. Fuller	August 19, 1994	8:30 a.m.

Dubuque Bank & Trust

1398 Central

Dubuque, Iowa 52004-0778

(planned DRHS board member)

Mr. Steven P. Sesterhenn	August 19, 1994	1 p.m.

Cycare Systems, Inc.

One Cycare Plaza, Ste. 500

Dubuque, Iowa 52001

Barry Harris, Ph.D.	August 31, 1994	8:30 a.m.

Economists, Inc.

12323 20th St., N.W.

Ste. 600

Washington, D.C. 20036

Rule 30(b)(6) Deposition

Mercy Health Services	August 15, 1994	8:30 a.m.

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.

Rule 30(b)(6) Deposition

Finley Tri-States	August 16, 1994	1 p.m.

Health Group, Inc.

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

KPMG Peat Marwick	August 18, 1994	1:00 p.m.

4200 Norwest Center

90th S. Seventh Street

Minneapolis, MN 55402-3900

Subject Matter:

The efficiencies that may or will be achieved as a result of the proposed partnership between Mercy Health Center and The Finley Hospital.

DATED: July 19, 1994	___________________________

Mary Beth McGee

Eugene D. Cohen

Jessica N. Cohen

U.S. Department of Justice

Antitrust Division

555 4th Street, N.W., Room 9421

Washington, D.C. 20001

Tel: (202) 307-1027

Fax: (202) 514-1517

Attorneys for the United States