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, Defendants. __________________________________________
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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 | Robert Khanna of Citigroup
| New York City | To be agreed | | Sammi Siddiqui of Citigroup
| New York City | To be agreed | | Robert Willumstad of Citigroup
| New York City | To be agreed | | Infistar Corporation 3490 Piedmont Rd., Suite 910 Atlanta, Georgia 30305 by its chief executive officer, Jerry D. Craft (a subpoena duces tecum will be served on Infistar)
| At a time and place to be agreed | At a time and place to be agreed | | William L. Powar, former Visa International executive
| At a time and place to be agreed | At a time and place to be agreed | | Mark Tonneson, member of the Visa International Board of Directors
| At a time and place to be agreed | At a time and place 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. October 22, 1999 | |