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​​​Discovery Requests

R.J. Reynolds Tobacco Company's index to documents provides information concerning the document requests to which documents have been produced in various civil smoking and health cases. 

This page helps you review the text of the requests that resulted in the production of one or more documents to this website under the terms of the Master Settlement Agreement. 

With respect to this information, please note:

  1. For ease of reference, the text on this site only reflects the text of discovery requests served upon R.J. Reynolds Tobacco Company where one or more of the responsive documents has been posted to this website under the terms of the Master Settlement Agreement and Order #1015 as modified by Order #27 Remand. 
  2. This site does not contain the definitions used by the parties in interpreting the document requests. 
  3. This site does not contain the text of R.J. Reynolds Tobacco Company's responses or objections to the discovery requests. 
  4. The scope of documents ultimately produced in most cases reflect extensive discussions and conferences among counsel and, in some cases, issuance of court orders that modified or other wise limited the scope of production. These clarifications and modifications of the production obligations, whether by agreement or by court order, are not reflected on this site. 
  5. Many documents that may have been responsive to a particular request may not appear as such on this website for a variety of reasons. These reasons may include: the documents are confidential and subject to protective order, the documents are subject to claims of attorney-client privilege and/or attorney work product, responsive documents were already produced in prior litigation and have already been posted to the website and are designated as responsive to the first case that resulted in the website posting.

Please use the menu on the left-hand side of this page to select the series of requests in which you would like to review.

Information regarding the document requests to which documents have been produced in smoking and health cases other than State of Minnesota, et al. v. Philip Morris, Inc., et al. and United States of America v. Philip Morris USA, Inc., et al. is located in "Case Identifier Information" section of this site.​