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UNITED STATES DISTRICT COURT
TO: ALL DEFENDANTS' COUNSEL
PLEASE TAKE NOTICE that plaintiff, the United States of America, will take the depositions upon oral examination of the following parties, commencing at 9 a.m. on the dates indicated (unless otherwise agreed), and continuing from day to day until completion, at locations to be mutually agreed upon with counsel for each deponent. The column entitled "# of Days" sets forth the Government's current best estimate of the number of days necessary to complete the deposition. This information is provided as a courtesy to defendants and is not intended to bind the Government with respect to the length of the deposition. The column entitled "Videotape" is intended to describe the Government's current intention as to whether that deposition will be videotaped. Should the Government's expectations with respect to the length of the deposition or its videotapin g change, the Government shall so inform counsel.
In addition to the specific individuals listed above, the Government also will take the deposition upon oral examination, pursuant to Fed. R. Civ. P. 30(b)(6), of the person(s) at (i) Visa International and (ii) MasterCard knowledgeable with respect to the effects on competition between and among Visa, MasterCard, and American Express as a result of the actual or expected issuance of American Express cards by member banks of Visa and/or MasterCard to consumers in the following locations: (a) Puerto Rico, (b) United Kingdom, (c) Israel, (d) France, (e) Portugal, (f) Turkey, and (g) Canada. The Government requests that these 30(b)(6) depositions take place on September 22, 1999 for the Visa witness(es) and September 25, 1999 for the MasterCard witness(es). The Government further requests that counsel identify for the Government, on or before August 1, 1999, the person(s) Visa International and MasterCard intend to put forth as their witnesses for these Rule 30(b)(6) depositions.
You are invited to attend and participate in each of these depositions.
Dated: Washington, D.C.