IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

                          IN AND FOR NEW CASTLE COUNTY                                  -  :       
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EDWARD HANNA,                                 >                            c  I(                   
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                 Plaintiff,                   >                            :
                                              >       Civil Action No.     r                     
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PRIMARY HEALTH SYSTEMS, INC.                  )                                          --,,:     
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                 Defendant.                   >

                      MOTION FOR EXPEDITED PROCEEDINGS

                 Plaintiff hereby moves the Court, pursuant to Rules 12(a) and 173 of the

Rules of the Court of Chancery, for the entry of an order in the form attached hereto,

expediting the proceedings in this action by requiring that defendant answer the

complaint by Monday, September 7, 1998, and by scheduling the trial of this action to

begin before Wednesday, September 16, 1998. The reasons for this motion are set forth

below.

                                        Background

          1.     On August 21, 1998, plaintiff Edward Hanna ("Hanna"), a holder of

record of the class B common stock of defendant Primary Health Systems, Inc. ("PHS"  or

the "Company"), made and mailed a written demand (the "Demand") in accordance with

Section 220 of the Delaware General Corporation Law demanding the right to inspect

and copy the stock list and certain specified books and records of the Company.

          2.     The Demand was sent on August 21, 1998, via certified mail to PHS at

both the office of its registered agent for service of process in Delaware and at its