FTC et al. v. College of Physicians-Surgeons of Puerto Rico, et al.

UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF PUERTO RICO

FEDERAL TRADE COMMISSION
and
THE COMMONWEALTH OF PUERTO RICO, Plaintiffs,

COLLEGE OF PHYSICIANS-SURGEONS OF PUERTO RICO, a corporation,
CENTRALMED INC., a corporation,
FAJARDO GROUP PRACTICE, INC. a corporation, and
NORTE MED, INC., a corporation, Defendants.

CIVIL NO.

STIPULATION

It is stipulated by and between the undersigned parties that:

(1) the parties consent that the Court may file and enter a Final Order and Stipulated Permanent Injunction in the form attached to this Stipulation without further notice to any party and without further proceedings;

(2) The Defendants waive any objection to jurisdiction over the parties and over the subject matter for the purposes of this Final Order and Stipulated Permanent Injunction; and

(3) The Defendant waives any objections to venue for purposes of this Final Order and Stipulated Permanent Injunction.

COLLEGE OF PHYSICIANS-SURGEONS OF PUERTO RICO

By:

Adalberto Mendoza Vallejo, M.D.
President

Date

CENTRALMED INC.

By:

Guillermo J. Tirado Menéndez, M.D.
President

Date

FAJARDO GROUP PRACTICE, INC.

By:

Sara López Martin, M.D.
President

Date

NORTE MED, INC.

By:

Karl Lang, M.D.
President

Date

Osvaldo Carlo-Linares
Attorney for College of Physicians-Surgeons

Date

José Vázquez Garcia
Attorney for College of Physicians-Surgeons

Date

Jorge Mendín
Attorney for Fajardo Group Practice, Inc.

Date

Raul Tirado
Attorney for Norte Med, Inc.

Date

Paul J. Nolan
Counsel for the Federal Trade Commission

Date

Alice Au
Counsel for the Federal Trade Commission

Date

Karin F. Richards
Counsel for the Federal Trade Commission

Date

APPROVED:

Michael E. Antalics, Assistant Director
General Litigation I - Non-Merger Division

Michael Joel Bloom, Regional Director
New York Regional Office

Robert F. Leibenluft, Assistant Director
General Litigation - Health Care Division

Mark D. Whitener, Deputy Director
Bureau of Competition

William J. Baer, Director
Bureau of Competition

José Fuentes Agostini, Attorney General
of the Commonwealth of Puerto Rico
Department of Justice

Linda González, Assistant Attorney General
Office of Monopolistic Affairs
Department of Justice