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Brown & Williamson

Minnesota Attorney General Request Number Designations and Document Descriptions

The text of document requests, letter requests, and court orders from the Minnesota Attorney General's action is below. The documents produced by Brown & Williamson in response to document requests and letter requests were determined by court orders, applicable law, and agreements with the plaintiffs in that case.

[A] - GENERAL CORPORATE, CORPORATE ORGANIZATION, ETC. / REQUESTS A1-A15

[A1] Documents which fairly and representatively describe, illustrate or depict all names, functions or organizational structures and lines of reporting and/or authority of departments, divisions or groups within your company which were involved in any manner in research on smoking and health from 1952 until the present.

[A2] Documents which fairly and representatively describe, illustrate and depict all names, functions or organizational structures and lines of reporting and/or organizational departments, divisions or groups within your company which were involved in any manner in advertising, marketing or promotion of cigarettes from 1952 until the present.

[A3] All documents generated by, prepared for, reviewed by or received by your board of directors or any executive committee, including but not limited to minutes of meetings, presentation materials and notes or memoranda kept by attendees, which relate or refer to issues of smoking and health or to the advertising, marketing or promotion of cigarettes.

[A4] All documents from the files of, authored by or sent to any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company which relate or refer to issues of smoking and health or to the advertising, marketing or promotion of cigarettes.

[A5] All documents relating or referring to communications to or from a corporate affiliate regarding smoking and health or the advertising, marketing or promotion of cigarettes.

[A6] All documents relating or referring to the establishment, formation or incorporation of the Council for Tobacco Research (or the Tobacco Industry Research Committee).

[A7] All documents relating or referring to the establishment, formation or incorporation of the Tobacco Institute.

[A8] All documents relating or referring to the establishment, formation or incorporation of any corporation or entity (other than the Council for Tobacco Research or the Tobacco Institute) which has or had any purpose relating to smoking and health or to the advertising, marketing or promotion of cigarettes, including but not limited to research or the warehousing, storage or organization of documents.

[A9] All documents relating or referring to your company's membership in or affiliation with any corporation or entity (other than the Council for Tobacco Research or the Tobacco Institute) which has or had any purpose relating to smoking and health or to the advertising, marketing or promotion of cigarettes, including but not limited to research or the warehousing, storage or organization of documents.

[A10] All documents relating or referring to the Literature Retrieval Division ("LRD").

[A11] All documents relating or referring to LS, Inc.

[A12] All documents relating or referring to a determination or decision of whether to conduct research involving smoking and health or research involving the advertising, marketing or promotion of cigarettes in any location outside of the United States.

[A13] All documents relating or referring to any communications with the United States Justice Department or any other defendant in this case regarding antitrust issues in the tobacco industry.

[A14] All documents relating or referring to corporate decisions regarding diversification in view of smoking and health issues.

[A15] All insurance policies which may afford coverage in the present case.

[B] - SALES AND PROFITS / REQUESTS B16-B20

[B16] All documents which summarize profits from cigarette sales in the United States for each year since 1952, by company and by the industry.

[B17] Documents which fairly and representatively summarize the sales of cigarettes (in terms of numbers of cigarettes or packs sold and in terms of dollars), by company and by the industry in the United States, for each year since

[B18] All documents which summarize (or from which it is possible to calculate) the sales and profits of cigarettes in the State of Minnesota for each year since 1952, by company and by the industry.

[B19] All documents which summarize the advertising, marketing and promotional expenditures for cigarettes, by company and by the industry, for each year since 1900 in the United States and in the State of Minnesota.

[B20] Documents which fairly and representatively describe, illustrate or depict the market share for cigarettes, by company, for each year since 1952 in the United States and in the State of Minnesota.

[C] - DOCUMENTS / REQUESTS C21-C23

[C21] All documents relating or referring to the sending or transfer (or potential sending or transfer) of documents regarding smoking and health or the advertising, marketing or promotion of cigarettes from your company to a corporate affiliate or to a third party for any purpose, including but not limited to storage, warehousing, indexing or destruction.

[C22] All documents relating or referring to the destruction or the potential destruction of documents involving issues of smoking and health or the advertising, marketing or promotion of cigarettes.

[C23] [This category intentionally left blank].

[D] - HEALTH CARE COSTS / REQUESTS D24-D25

[D24] All documents relating or referring to the issue of health insurance rates for smokers (or for smokers versus nonsmokers).

[D25] All documents relating or referring to health care costs for smokers (or for smokers versus nonsmokers).

[E] - GENERAL SMOKING AND HEALTH / REQUESTS E26-E39

[E26] All documents relating or referring to the establishment or maintenance or change of your publicly-stated position that it is not proven that smoking causes disease.

[E27] All documents relating or referring to the establishment or maintenance or change of your publicly-stated position that smoking (or nicotine) is not addictive.

[E28] All documents relating or referring to agreements, directives, discussions or recommendations regarding policies or positions on issues involving the health hazards of cigarettes.

[E29] All documents relating or referring to agreements, directives, discussions or recommendations regarding policies or positions on issues involving the addictiveness of cigarettes (or nicotine).

[E30] All documents relating or referring to agreements, directives, discussions or recommendations involving the release, provision, withholding or suppressing of information on smoking and health to the public or to government authorities.

[E31] All documents relating or referring to agreements, directives, discussions or recommendations of attorneys (in-house or outside counsel) involving the release, provision, withholding or suppressing of information on smoking and health to the public or to government authorities.

[E32] All documents relating or referring to agreements, directives, discussions or recommendations to terminate or not undertake research on smoking and health.

[E33] All documents relating or referring to agreements, directives, discussions or recommendations of attorneys (in-house or outside counsel) to terminate or not to undertake research on smoking and health.

[E34] All documents relating or referring to the actions of attorneys (in-house or outside counsel) in directing, controlling or commissioning research on smoking and health.

[E35] All press releases issued by a defendant in the present case relating or referring to issues of smoking and health.

[E36] All public statements by a defendant in the present case relating or referring to issues of smoking and health.

[E37] All documents relating or referring to smoking and health or to the advertising, promotion or marketing of cigarettes exchanged or shared between your company and any of the following entities:

    Any other defendant in the present case;
  • Hill & Knowlton;
  • Ted Bates & Co.;
  • Tiderock Corp.;
  • Any tobacco or cigarette trade group or organization in England;
  • Any tobacco or cigarette company in England;
  • The Roper organization;
  • Minnesota Candy and Tobacco Association;
  • Minnesota Convenience Stores Association;
  • Minnesota Grocers Association;
  • Minnesota Smokers' Rights Coalition.

[E38] All documents relating or referring to the cessation of Hill & Knowlton's representation of the Council for Tobacco Research, the Tobacco Institute or any other defendant in the present case.

[F] - GENERAL RESEARCH / REQUESTS F39-F60

[F39] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the biological activity of cigarettes which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director or your company or any member of any executive committee of your company or any other defendant in the present case.

[F40] All documents including reports, notes, research, memoranda and evaluations, relating or referring to the effects of carbon monoxide on smokers which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any defendant in the present case.

[F41] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible relationship between smoking and cancer which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F42] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible relationship between smoking and heart disease which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F43] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible relationship between smoking and arteriosclerosis which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F44] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible relationship between smoking and stroke which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F45] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible relationship between smoking and emphysema which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F46] All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship between smoking and chronic obstructive pulmonary disease which were written by or shared with any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[F47] All documents relating or referring to the health hazards or potential or possible health hazards of cigarette additives which were written by or shared by any member of your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any executive committee of your company or any other defendant in the present case.

[F48] All documents relating or referring to the effects or potential or possible effects of smoking on pregnant women or their fetuses or children.

[F49] All documents relating or referring to the formation or potential formation of the Cigarette Research Institute.

[F50] All documents relating or referring to the "Industry Research Committee."

[F51] All documents generated by, prepared for, reviewed by or received by the Council for Tobacco Research industry technical committee, including but not limited to minutes of meetings, presentation materials and notes or memoranda kept by attendees, which relate or refer to issues of smoking and health.

[F52] All documents relating or referring to research conducted by the American Medical Association (AMA) on smoking and health, the funding of such research by the tobacco industry and the termination of the AMA research on smoking and health.

[F53] All documents relating or referring to the Auerbach and Hammond study of smoke inhalation by beagles.

[F54] All documents relating or referring to the undertaking or cessation of research on smoking and health by Hugh Fudenberg.

[F55] All documents relating or referring to the undertaking or cessation of research on smoking and health by Geoffrey Ashton.

[F56] All documents relating or referring to the undertaking or cessation of research on smoking and health by Mason Research Institute.

[F57] All documents relating or referring to the undertaking or cessation of research on smoking and health by the Bio-Research Institute and/or Freddy Homberger.

[F58] All documents relating or referring to the undertaking or cessation of research on smoking and health by the Bio-Research Institute and/or Microbiological Associates.

[F59] All documents to or from, or relating or referring to, Dr. Gio Gori.

[F60] All documents to or from, or relating or referring to, T.C. Tso.

[G] - SAFER CIGARETTES / REQUESTS G61-G70

[G61] All documents relating or referring to the development or attempted development of a "safer" cigarette which were written by or shared with any member or your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[G62] All documents relating or referring to research of catalysts for cigarettes which were written by or shared with any member or your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[G63] All documents relating or referring to whether or not to market a "safer" cigarette.

[G64] All documents to or from or copied to attorneys (in-house or outside counsel) relating or referring to whether or not to market a "safer" cigarette.

[G65] All documents relating or referring to representations to make or refrain from making in the advertising, marketing or promotion of "safer" cigarettes.

[G66] All documents relating or referring to the Liggett XA, XA-5001, Tame, Bio Res or a Liggett "safer" cigarette.

[G67] All documents relating or referring to efforts to sell, market or license the XA, XA-5001, Tame, Bio Res or a Liggett "safer" cigarette technology to a third party.

[G68] All documents relating or referring to the National Cancer Institute work involving development of a "safer" cigarette.

[G69] All documents relating or referring to the research, development or marketing of Eclipse and Premier cigarettes which were written by or shared [sic] any member or your board of directors, any chief executive or chief executive officer of your company, any president of your company, any research director of your company or any member of any executive committee of your company or any other defendant in the present case.

[G70] All patents and patent applications, whether filed in the United States or in another country, referring or relating to a "safer" cigarette.

[H] - NICOTINE AND ADDICTION / REQUESTS H71-H91

[H71] All documents relating or referring to the pharmacological or physiological effects of nicotine.

[H72] All documents relating or referring to nicotine addiction, dependence, habituation, tolerance or withdrawal

.

[H73] All documents relating or referring to smoking cessation.

[H74] All documents relating to the numbers or percentages of smokers who attempt to quit smoking -- successfully or unsuccessfully.

[H75] All documents relating or referring to the determination of target levels of nicotine in cigarettes.

[H76] All documents relating or referring to the effects on smokers of different levels of nicotine.

[H77] All documents relating or referring to the issue of minimum levels of nicotine, minimum doses of nicotine or how much nicotine reduction will be acceptable to smokers.

[H78] All documents relating or referring to nicotine analogues.

[H79] All documents relating or referring to the monitoring, controlling, manipulating, altering, adjusting, restoring or addition of nicotine to tobacco or any part of the cigarette during any step during the production of cigarettes, from the breeding, growing and purchasing of tobacco to the manufacture of the final product.

[H80] All documents relating or referring to affecting, altering or increasing the delivery, effectiveness, impact, bioavailability or absorption of nicotine by any manner, including but not limited to altering or adjusting alkalinity or pH levels, the addition of any substances (including but not limited to nicotine or nicotine extract), the breeding of tobacco or the design of cigarettes (including but not limited to the design of cigarette filters).

[H81] All documents relating or referring to the effect of ammonia on nicotine.

[H82] All documents relating or referring to acetaldehyde.

[H83] All documents relating or referring to research, testing, test marketing or studies involving the relationship of nicotine to taste or flavor.

[H84] All documents relating or referring to the relationship of nicotine levels to tar levels in cigarettes.

[H85] All documents relating or referring to the development of a tobacco plant with altered levels -- increased or decreased -- of nicotine.

[H86] All documents relating or referring to blending tobacco to alter the nicotine content of tobacco in cigarettes.

[H87] All documents relating or referring to the development or attempted development or testing of a nicotine-free cigarette or a cigarette with nicotine levels significantly reduced from current brands.

[H88] All documents relating or referring to health hazards or potential health hazards of nicotine, including but not limited to cancer and cardiovascular disease.

[H89] All documents relating or referring to the January 1972 conference in St. Martin on smoking (including all tape or video recordings).

[H90] All patents and patent applications, whether filed in the United States or in another country, referring or relating to the ability to control, alter or manipulate the level of nicotine or to affect the delivery, effectiveness, impact, bioavailability or absorption of nicotine.

[H91] All documents relating or referring to the effects of nicotine on persons age 18 or younger (or children, adolescents or young adults).

[I] - YOUTH / REQUESTS I92-I101

[I92] All documents relating or referring to the initiation of smoking or why persons begin smoking.

[I93] All documents relating or referring to the advertising, marketing or promotion of cigarettes to persons age 18 or under (or children, adolescents or young adults).

[I94] All documents relating or referring to smoking cessation efforts, successful or unsuccessful, among persons age 18 or under (or children, adolescents or young adults).

[I95] All documents relating or referring to focus groups, surveys, polls, interviews, studies, research or information regarding the number of smokers or prevalence of smoking among persons age 18 or under (or children, adolescents or young adults) for your cigarette brands or any other cigarettes.

[I96] All documents relating or referring to focus groups, surveys, interviews, polls, studies, research or marketing plans involving smoking and persons age 18 or under (or children, adolescents or young adults).

[I97] All documents relating or referring to focus groups, surveys, interviews, polls, studies or research regarding the attitudes, perceptions or behaviors of persons age 18 or under (or children, adolescents or young adults) regarding cigarettes or cigarette advertising, marketing or promotion.

[I98] All documents relating or referring to industry or company guidelines or codes relating to advertising, marketing or promoting cigarettes to persons age 18 or under (or children, adolescents or young adults).

[I99] All documents relating or referring to your efforts or cigarette industry efforts to prevent or discourage persons under age 18 (or children, adolescents or young adults) from smoking cigarettes.

[I100] All documents relating or referring to the placement of cigarette billboards near schools or playgrounds.

[I101] All documents relating or referring to the effects of point-of-sale advertising on persons age 18 or younger (or children, adolescents or young adults).

[J] - SURVEYS, MARKET RESEARCH AND ADVERTISING / REQUESTS J102-J114

[J102] All documents relating or referring to surveys, polls, interviews, focus groups, studies or research involving the attitudes, understandings or beliefs of smokers regarding the health hazards or addictiveness of cigarettes.

[J103] All documents relating or referring to the sociology or psychology of smokers in evaluating, understanding or reacting to information regarding the health hazards or addictiveness of cigarettes.

[J104] All documents relating or referring to the effectiveness of the warning labels on cigarettes.

[J105] All documents relating or referring to research, surveys, focus groups, interviews, studies or information on consumers' views or perceptions concerning the levels of tar and nicotine in cigarettes.

[J106] All documents relating or referring to the effects of cigarette advertising.

[J107] All documents relating or referring to the effects of anti-smoking advertising or the Fairness Doctrine on smoking.

[J108] All documents relating or referring to the Roper Proposal.

[J109] All documents relating or referring to research or polls by the Roper organization on smoking and health.

[J110] All documents relating or referring to "editorial-type" advertisements or promotions discussing or addressing the relationship between smoking and health, including but not limited to drafts of such advertisements or promotions, memoranda relating or referring to such advertisements or promotions and the advertisements and promotions actually utilized. (The term "editorial-type" advertisements or promotions is meant to refer to materials such as the 1954 "A Frank Statement to Cigarette Smokers" or the R.J. Reynolds ad "Of cigarettes and science," as opposed to advertisements specific to particular brands of cigarettes.)

[J111] All documents relating or referring to discussions or decisions by more than one cigarette company to refrain from certain types of advertising or promotion (for example, advertising with health claims).

[J112] All documents summarizing the number or percentage of smokers who switch cigarette brands.

[J113] All documents relating or referring to a decision by any advertising, marketing or promotional firm to refuse to undertake, to cease, to decline or to resign from any advertising, marketing or promotion work for cigarettes because of any issue involving smoking and health.

[J114] All documents relating or referring to the placement of advertisements, promotional or marketing materials at sporting or entertainment events which also relate or refer to the displaying of such materials on television.

[K] - FTC TESTING / REQUESTS K115-K123

[K115] All documents relating or referring to differences or discrepancies between Federal Trade Commission testing methods and actual intake of tar or nicotine by smokers.

[K116] All documents relating or referring to methods of designing or manufacturing cigarettes so that the actual intake of tar or nicotine by smokers would be less accurately reflected by the Federal Trade Commission testing methods or would be different from the levels reflected by the Federal Trade Commission testing methods.

[L117] All documents relating or referring to the placement of ventilation holes in the filters of cigarettes in a manner which might affect or alter the Federal Trade Commission testing results as compared with the actual smoking by persons.

[L] - OTHER LITIGATION

[L118] All transcripts or depositions (and accompanying deposition exhibits) of your officers, employees or experts from all other litigation, prior or pending, involving smoking and health. If such depositions are on computer disk or on video, provide all such disks and videos.

[L119] All exhibits from all other litigation, prior or pending, involving smoking and health, including all parties' trial exhibits and all exhibits attached to any pleading by any party.

[L120] All trial transcripts for all other litigation, prior or pending, involving smoking and health. If such transcripts are on computer disk, provide all such disks.

[L121] All documents produced by your company in response to document requests, as well as interrogatories and requests for admission responded to by your company, from the following cases:

  1. Green v. American Tobacco
  2. Pritchard v. Liggett & Myers Tobacco
  3. Thayer v. Liggett & Myers Tobacco

[L122] All privilege logs produced by your company in any litigation, prior or pending, involving smoking and health.

[L123] All document retention and nondestruct orders for all other litigation, prior or pending, involving smoking and health.

[M] - ADDITIONAL REQUESTS TO B&W / REQUESTS M124-M132

[M124] All documents produced by Brown & Williamson in response to document requests in all other litigation, prior or pending, involving smoking and health; all document requests served on Brown & Williamson in such litigation; all correspondence between Brown & Williamson and plaintiffs regarding plaintiffs' document requests in such litigation, and all motions to compel brought against Brown & Williamson in such litigation (with all briefs by plaintiffs and Brown& Williamson and all resulting court orders).

[M125] All documents relating or referring to the research, development or marketing of Y-1.

[M126] All documents from the files of, authored by or sent to Dr. Robert B. Griffith which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M127] All documents from the files of, authored by or sent to Timothy V. Hartnett which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M128] All documents from the files of, authored by or sent to I. W. Hughes which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M129] All documents from the files of, authored by or sent to T. F. Riehl which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M130] All documents from the files of, authored by or sent to Thomas E. Sandefur which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M131] All documents from the files of, authored by or sent to Dr. Irwin Tucker which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[M132] All documents from the files of, authored by or sent to Addison Yeaman which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.

[N] - FIRST JURISDICTIONAL REQUESTS / REQUESTS N1-N37

[N1] All corporate organization charts and documents which establish or demonstrate lines of communication and reporting between or among any of the following entities: BAT Group, BAT, British-American Tobacco, Brown & Williamson (or any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent), from 1952 to the present.

[N2] All documents relating to the organization, structure and membership of the BAT Group, from 1952 to the present.

[N3] All articles of incorporation and bylaws for BAT Group, BAT, British-American Tobacco, Brown & Williamson and any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent, from 1952 to the present.

[N4] All documents which demonstrate, establish or relate to BAT's ability, power, authority or responsibility to control or participate in the affairs of or advise Brown & Williamson (or any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent) and/or British-American Tobacco, including but not limited to statements of policy, policy manuals, policies relating to exercising control over subsidiaries, or operational or management guidelines from 1976 to the present.

[N5] All documents which demonstrate, establish or relate to BAT Group's ability, power, authority or responsibility to control or participate in the affairs of or advise Brown & Williamson (or any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent) and/or British-American Tobacco, including but not limited to statement of policy, policy manuals, policies relating to exercising control over subsidiaries, or operational or management guidelines, from 1952 to the present.

[N6] All documents which demonstrate, establish or relate to British-American Tobacco's ability, power, authority or responsibility to control or participate in the affairs of or advise Brown & Williamson (or any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent), including but not limited to statements of policy, policy manuals, policies relating to exercising control over subsidiaries or operational or management guidelines, from 1952 to the present.

[N7] All documents containing, referring to or memorializing any agreement or communication of any type between any members of the BAT Group -- including but not limited to BAT, British-American Tobacco and Brown & Williamson -- which demonstrate, establish or relate to the structure, control, management, operation or financing of BAT Group research and/or development or to the control, establishment, consultation or management of BAT Group policies on smoking and health.

[N8] All documents, including but not limited to organization charts, correspondence, memos and notes, regarding the structure, control, management, organization or financing of BAT Group research and/or development organizations performing work on smoking and health, including but not limited to the BAT Group Research and Development Centre and any predecessor or successor research entity.

[N9] All documents regarding the policies and/or guidelines of BAT Group research and/or development.

[N10] All documents relating to smoking and health, including but not limited to memoranda and research reports, generated by or for BAT Group or any member of BAT Group.

[N11] All cigarette design handbooks provided to one or more members of the BAT Group by the BAT Group or another member of the BAT Group.

[N12] The 1983 "BAT Industries guideline" regarding Group R&D, as referred to on page 1 of the report of the 1983 research conference in Brazil (document number BW-W2-01829 as submitted to the U.S. House of Representatives, Committee on Energy and Commerce, Subcommittee on Health and the Environment).

[N13] All agreements, understandings or directives between Brown & Williamson and the BAT Group or any member of the BAT Group regarding research and/or development activities relating to smoking and health, and all correspondence, memos, notes or any other documents regarding such agreements.

[N14] All agreements, understandings or directives between Brown & Williamson and the BAT Group or any member of the BAT Group regarding the funding of research and/or development activities regarding smoking and health, and all correspondence, memos, notes or any other documents regarding such agreements, payments under such agreements and discussions about such agreements.

[N15] The 1961 agreement between British-American Tobacco and Brown & Williamson to pool research efforts, and all amendments, revisions or suggested amendments or revisions thereto.

[N16] The July 9, 1969 R&D Cost and Risk Pooling Agreement between British-American Tobacco and Brown & Williamson and amendments, revisions or suggested amendments or revisions thereto, including but not limited to the February 7, 1977 letter.

[N17] All documents relating to conferences or meetings on smoking and health attended by your company and at least one other member of the BAT Group.

[N18] All research and/or development documents regarding the development of a "safer" cigarette which were shared with your company by the BAT Group or any member of the BAT Group, including but not limited to documents relating to the feasibility of designing "safer" cigarettes and decisions whether to market "safer" cigarettes.

[N19] All research and/or development documents relating to cigarettes with various levels or deliveries of nicotine or regarding nicotine analogues and all documents relating to decisions whether to market any such cigarettes which were shared with your company by the BAT Group or any member of the BAT Group.

[N20] All documents relating to the involvement of any member of the BAT Group (other than or in addition to Brown & Williamson) in the research, development or marketing of Y-1.

[N21] All documents relating to agreements, directives, discussions, or recommendations regarding corporate policies on smoking and health relating to Brown & Williamson and at least one other member of the BAT Group.

[N22] All documents relating to agreements, directives, discussions, or recommendations for the BAT Group or any member of the BAT Group regarding the release or provision of information by Brown & Williamson regarding smoking and health to the public and/or to government authorities.

[N23] All communications between Addison Yeaman and British-American Tobacco or BAT Group or any member of the BAT Group regarding whether to provide information to the U.S. Surgeon General on smoking and health.

[N24] All documents regarding the sending or transfer (or potential sending or transfer) of documents regarding smoking and health from BAT Group or one member of the BAT Group to BAT Group or another other member of the BAT Group or to a third party for any purpose, including but not limited to storage, warehousing, indexing or destruction.

[N25] All documents which relate to document retention or destruction policies of BAT Group, BAT, British-American Tobacco and/or Brown & Williamson, from 1952 to the present.

[N26] All documents which relate to the destruction or the potential destruction of documents relating to smoking and health.

[N27] All communications between or shared by legal counsel of your company and any other member of the BAT Group regarding issues of smoking and health.

[N28] All reports to shareholders, directors' reports and reports and accounts for BAT, British-American Tobacco and Brown & Williamson from 1952 to the present.

[N29] All documents relating to an express or implied agreement by BAT to assume any debts or liabilities of British-American Tobacco.

[N30] All documents summarizing any money or other assets transferred to BAT by Brown & Williamson, directly or indirectly.

[N31] All documents summarizing all revenue and profit derived by BAT from Brown & Williamson, directly or indirectly.

[N32] All agreements or understandings by BAT or any other member of the BAT Group to pay for part or all of any judgment against Brown & Williamson, through insurance or any other means.

[N33] All documents summarizing -- by brand and by company -- sales of cigarettes by any member of BAT Group in the United States.

[N34] All documents summarizing -- by brand and by company -- sales of cigarettes by any member of BAT Group in the State of Minnesota.

[N35] All documents relating to discussions for smoking and health issues at board of directors meetings which reference or refer to the BAT Group or any member of the BAT Group, including meeting agendas, minutes, notes of any board members or attendees, and documents generated by, prepared for, reviewed by or received by board members.

[N36] All documents from the files of, authored by or sent to Thomas E. Sandefur relating to the corporate relationship between or among Brown & Williamson and BAT Group, BAT or British-American Tobacco.

[N37] All documents from the files of, authored by or sent to Thomas E. Sandefur relating to research and/or development or policy issues on smoking and health which originated with or were shared with any member of BAT Group.

[O] - SECOND JURISDICTIONAL REQUESTS / REQUESTS O1-O2

[O1] All documents relating to the 1979 corporate reorganization, in which British-American Tobacco was moved out of the chain of ownership of Brown & Williamson, which were either publicly released or filed with any government or regulatory agency.

[O2] All documents relating or referring to any change in corporate chains of command, corporate lines of communication, or the ability, power, authority or responsibility of British-American Tobacco to control or participate in the affairs of or advise Brown & Williamson (or any corporate intermediary companies in the chain of ownership between Brown & Williamson and its ultimate parent), arising out of the 1979 corporate reorganization, in which British-American Tobacco was moved out of the chain of ownership of Brown & Williamson.

[P] - SMOKELESS TOBACCO

[P] Documents relating to smokeless tobacco.

[Q] - INTERROGATORY NO. 16 (outside research on smoking/health)

[Q] Unpublished research reports on smoking and health provided to or shared with, in whole or in part, Brown & Williamson.

[R] - PLAINTIFF'S FOURTH REQUEST FOR PRODUCTION (MERITS)

[R1] [This category intentionally left blank.]

[R2] All documents relating or referring to the use of Chemosol in cigarettes or Chemosol cigarettes.

[R3] All documents relating or referring to research by Hazelton on Chemosol, "safer" cigarettes or smoking and health.

[R4] All documents relating or referring to U.S. Patents 3,258,015 and/or 3,356,094 or their foreign corresponding patents.

[R5] All documents relating or referring to nicotine replacement treatments or devices, including but not limited to nicotine patches, nicotine gum and nicotine aerosol.

[R6] All documents relating or referring to projections or estimations of the impact on sales or profits of successful efforts at smoking cessation.

[R7] All annual research and development budgets for cigarettes and/or smoking and health, including but not limited to budgets depicting total expenditures on research and development as well as expenditures broken out by departments, divisions or types of research and development, from 1946 to the present.

[R8] All reports on scientific research relating to smoking and health which were sent to attorneys (in-house or outside) working for or on behalf of any defendant in this case.

[R9] All documents relating or referring to the rating or comparison of different brands or types or prototypes of cigarettes by biological activity or biological parameters, including but not limited to documents which relate or refer to whether or not to use such rating or comparison on commercial cigarettes or in public disclosures.

[R10] All consent decrees or orders of the Federal Trade Commission regarding the advertising, marketing or promotion of cigarettes.

[R11] All documents relating or referring to Project Ariel.

[R12] All research reports on smoking and health sent from BAT Group Research & Development Centre to Wyatt, Tarrant & Combs.

[R13] The 1991 handbook for leaf blenders (as referenced in the Wall Street Journal article dated October 18, 1995).

[R14] The October 23, 1992 document entitled, "PM's Global Strategy: Marlboro Product Technology" (as referenced in the Wall Street Journal article dated October 18, 1995).

[S] - PLAINTIFF'S SEVENTH REQUEST FOR PRODUCTION

[S1] All pre-July 1969 print and electronic (radio and television) cigarette advertisements and promotions.

[S2] All documents which summarize where pre-July 1969 print and electronic cigarette advertisements were placed (i.e. media outlets).

[T1] All documents relating to agreements, understandings, or discussions on product standards, designs, ingredients, specifications, or additives among one or more defendants;

[T2] All documents relating to Maximum Use Levels, or MUL, of any cigarette additives or ingredients; and

[T3] All documents relating to agreements, understandings, or discussions relating to the licensing or use by one or more defendants of another defendant's patent (patents) relating to smoking and health

.

[U1] Documents sufficient to disclose all specifications and all ingredients for each brand of cigarettes marketed in Minnesota from 1954 to the present by you or a corporate affiliate.

[U2] Documents sufficient to disclose the full formula for each brand of cigarettes marketed in Minnesota from 1954 to the present by you or a corporate affiliate.

[V1] Documents related to the use of freon in tobacco processing.

[V2] All pre-July 1969 print and electronic (radio and television) cigarette advertisements and promotions.

[W] - PLAINTIFF'S EIGHTH REQUEST FOR PRODUCTION

[W1] All documents relating to lobbying activities in, or relating to, Minnesota, on behalf of you or any other defendant in this litigation, directly or indirectly, relating to any legislation or proposed legislation relating to the sale or distribution of cigarettes to minors.

[W2] All documents relating to lobbying activities in, or relating to, Minnesota, on behalf of you or any other defendant in this litigation, directly or indirectly, relating to tobacco control efforts by the State of Minnesota, including but not limited to tobacco use prevention programs, community and statewide grant projects, ASSIST, the Minnesota Clean Indoor Air Act, legislation prohibiting smoking in health care facilities, legislation limiting the locations for tobacco vending machines, legislation prohibiting the free distribution of cigarettes or tobacco products except for single serving samples in tobacco stores, and legislation requiring that all K-12 school districts be tobacco-free.

[W3] All documents relating to lobbying activities in, or relating to, Minnesota, on behalf of you or any other defendant in this litigation, directly or indirectly, relating to cigarette excise tax legislation or proposed cigarette excise tax legislation.

[X] - 9/4/97 Order

[X1] Any lists, compilations, or other documents which identify on a brand-by-brand and/or year-by-year basis, the ingredients, chemical formulae, and/or processes for any cigarettes sold in Minnesota between 1954 and 1994, irrespective of whether such lists or compilations were prepared by or at the direction of attorneys in anticipation of litigation. If such documents contain opinion work product, however, such opinion work product shall be redacted from the documents produced to Plaintiffs, and unredacted versions of such documents shall be filed, under seal, with the Court.

[X2] All defendants except CTR and TI shall state whether the defendant has ever used any computer programs or models in the design of cigarettes. If the answer is in the affirmative, then said defendant shall produce to plaintiffs a detailed description of the computer program(s) or computer model(s), details concerning the input and output design parameters, and the actual computer models for any cigarettes sold in Minnesota from 1954 to 1994. In addition, said defendant shall produce all other documents referencing or discussing the applicability of the computer program to any of the issues raised in plaintiffs' prior discovery including smoking and health, nicotine delivery, or addiction.

[Y1] [This category intentionally left blank].

[Z] - Documents Re: "Layers' Special Project"

[Z1] Lawyers' Special Projects documents.

[AA] - 11-14-97 Order

[AA] Each and every document, notice, memorandum, note, recording, or memorialization of any type or in any form in their possession, custody, or control of their outside counsel or any corporate affiliate, that contains, embodies, reflects, or alludes to any joint defense agreements or understandings (whether oral, written, "hinted at" or suggested in any fashion) with any other defendant (or corporate affiliate, past or present, of any other defendant) to this action, from 1954 to the present​.​