IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

____________________________________ ) ) ) Plaintiff, ) ) v. ) ) UPM-KYMMENE OYJ, et al., ) ) Defendants. ) ) ____________________________________) UNITED STATES OF AMERICA,

Civil No:

03 C 2528 (J. Zagel)

NOTICE TO THE COURT REGARDING THE UNITED STATES’ MOTION TO REQUIRE UPM-KYMMENE, OYJ TO MAKE AVAILABLE IN THE UNITED STATES RESPONSIVE DOCUMENTS AND ONE DEPONENT LOCATED IN FINLAND The United States originally provided the Court notice of its Motion to Require UPMKymmene Oyj to Make Available in the United States Responsive Documents and One Deponent Located in Finland, requesting that it be presented before the Court on Tuesday, May 13, 2003. The United States hereby notifies the Court that on May 11, 2003, defendant UPMKymmene Oyj (“UPM”) agreed to make its President and Chief Executive Officer, Juha Niemela, available in Washington, D.C., on May 19, 2003, for a deposition originally noticed for May 16, 2003, while no longer insisting on unrelated conditions that plaintiff considered unacceptable. This agreement renders moot the portion of plaintiff’s above-referenced motion that requested the Court to order UPM to make Mr. Niemela available for a deposition. A revised proposed order is attached to this notice. The United States also notifies the Court that with UPM’s consent, it has re-scheduled

presentation of the above-referenced motion before the Court to Thursday, May 15, at 10:15 am, or as soon thereafter as counsel may be heard, to discuss the remaining issue pertaining to UPM’s refusal to produce responsive documents from Finland.

Respectfully submitted, FOR PLAINTIFF UNITED STATES:

__/s/______________________________ Carla Stern Trial Attorney Department of Justice Antitrust Division 209 South LaSalle Street, Suite 600 Chicago, IL, 60604 (312) 353-6685

_____/s/___________________________ Claude Scott Weeun Wang Steven Kramer Karl Knutsen Michael Spector Michael Bishop Ihan Kim Trial Attorneys Department of Justice Antitrust Division Litigation I Section 1401 H Street, NW, Suite 4000 Washington, D.C. 20530 (202) 307-0997

Dated: May 12, 2003

2

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

____________________________________ ) ) ) Plaintiff, ) ) v. ) ) UPM-KYMMENE OYJ, et al., ) ) Defendants. ) ) ____________________________________) UNITED STATES OF AMERICA,

Civil No:

03 C 2528 (J. Zagel)

ORDER REQUIRING UPM-KYMMENE OYJ TO MAKE AVAILABLE IN THE UNITED STATES RESPONSIVE DOCUMENTS

For good cause shown, defendant UPM-Kymmene, Oyj (“UPM”) is ORDERED to properly respond to document requests calling for documents located in Finland.

Dated: May ______, 2003

UNITED STATES DISTRICT COURT JUDGE

CERTIFICATE OF SERVICE

I hereby certify that copies of the foregoing Notice to the Court Regarding the United States’ Motion to Require UPM-Kymmene Oyj to Make Available in the United States Responsive Documents and One Deponent Located in Finland were served by facsimile and first class mail upon each of the parties listed below: Christopher M. Curran White & Case LLP 601 Thirteenth Street, N.W., Suite 600 South Washington, D.C. 20005-3807 Telephone: (202) 626-3600 Facsimile: (202) 639-9355 Alan S. Madans Rothschild, Barry & Meyers 55 West Monroe Street, Suite 3900 Chicago, IL 60603-5012 Telephone: (312) 372-2345 Facsimile: (312) 372-2350 Counsel for defendants UPM-Kymmene Oyj and Raflatac, Inc. John D. French Faegre & Benson LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, MN, 55402-3901 Telephone: (612) 766-7000 Facsimile: (612) 766-1600 Thomas A. Doyle Baker & McKenzie One Prudential Plaza 130 East Randolph Drive Chicago, IL 60601 Telephone: (312) 861-8866 Counsel for defendants Bemis Company Inc. and Morgan Adhesives Company

May 12, 2003