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 |
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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 |
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