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Plaintiffs' First Set of Requests for Production of Documents to R.J. Reynolds Tobacco Company 

    GENERAL CORPORATE, CORPORATE ORGANIZATION, ETC.
  1. 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.
  2. 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 advertising, marketing, or promotion of cigarettes from 1952 until the present.
  3. 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.
  4. All documents from the files of, authored by or sent to any member of your board of directors, any chief executive or chief executive 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.
  5. 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.
  6. All documents relating or referring to the establishment, formation or incorporation of the Council for Tobacco Research (or the Tobacco Industry Research Committee).
  7. All documents relating or referring to the establishment, formation or incorporation of the Tobacco Institute.
  8. 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.
  9. 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.
  10. All documents relating or referring to the Literature Retrieval Division ("LRD").
  11. All documents relating or referring to LS, Inc.
  12. All documents re1ating or referring to a determination or decision of whether to conduct research involving smoking and health or research involving advertising, marketing or promotion of cigarettes in any location outside, of the United States.
  13. 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.
  14. All documents relating or referring to corporate decisions regarding diversification in view of smoking and health issues.
  15. All insurance policies which may afford coverage in the present case.

  16. SALES AND PROFITS

  17. All documents which summarize profits from cigarette sales in the United States for each year since 1952, by company and by the industry.
  18. 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 1900.
  19. 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.
  20. 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.
  21. 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.

  22. DOCUMENTS

  23. 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.
  24. 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.
  25. All documents relating or referring to document destruction policies of your company, from 1952 to the present.

  26. HEALTH CARE COSTS

  27. All documents relating or referring to the issue of health insurance rates for smokers (or for smokers versus nonsmokers).
  28. All documents relating or referring to health care costs for smokers (or for smokers versus nonsmokers).

  29. GENERAL SMOKING AND HEALTH

  30. 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.
  31. All documents relating or referring to the establishment or maintenance or change of your publicly-stated position that smoking (or nicotine) is not addictive.
  32. All documents relating or referring to agreements, directives, discussions or recommendations regarding policies or positions on issues involving the health hazards of cigarettes.
  33. All documents relating or referring to agreements, directives, discussions or recommendations regarding policies or positions on issues involving the addictiveness of cigarettes (or nicotine).
  34. 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.
  35. 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.
  36. All documents relating or referring to agreements, directives, discussions or recommendations to terminate or not undertake research on smoking and health.
  37. 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.
  38. 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.
  39. All press releases issued by a defendant in the present case relating or referring to issues of smoking and health.
  40. All public statements by a defendant in the present case relating or referring to issues of smoking and health.
  41. 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:
    1. Any other defendant in the present case;
    2. Hill & Knowlton;
    3. Ted Bates & Co.;
    4. Tiderock Corp.;
    5. Any tobacco or cigarette trade group or organization in England;
    6. Any tobacco or cigarette company in England;
    7. The Roper organization;
    8. Minnesota Candy and Tobacco Association;
    9. Minnesota Convenience Stores Association;
    10. Minnesota Grocers Association;
    11. Minnesota Smokers' Rights Coalition.
  42. 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.

  43. GENERAL RESEARCH

  44. 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 of your company or any member of any executive committee of your company or any other defendant in the present case.
  45. 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 other defendant in the present case.
  46. 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.
  47. 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.
  48. 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.
  49. 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.
  50. 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.
  51. All documents, including reports, notes, research, memoranda and evaluations, relating or referring to the relationship or potential or possible 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.
  52. All documents relating or referring to the health hazards or potential or possible health hazards of cigarette additives 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 executive committee of your company or any other defendant in the present case.
  53. All documents relating or referring to the effects or potential or possible effects of smoking on pregnant women or their fetuses or children.
  54. All documents relating or referring to the formation or potential formation of the Cigarette Research Institute.
  55. All documents relating or referring to the "Industry Research Committee."
  56. 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.
  57. 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.
  58. All documents relating or referring to the Auerbach and Hammond study of smoke inhalation by beagles.
  59. All documents relating or referring to the undertaking or cessation of research on smoking and health by Hugh Fudenberg.
  60. All documents relating or referring to the undertaking or cessation of research on smoking and health by Geoffrey Ashton.
  61. All documents relating or referring to the undertaking or cessation of research on smoking and health by Mason Research Institute.
  62. 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.
  63. 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.
  64. All documents to or from, or relating or referring to, Dr. Gio Gori.
  65. All documents to or from, or relating or referring to, T.C. Tso.

  66. SAFER CIGARETTES

  67. All documents relating or referring to the development or attempted development of a "safer" cigarette 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.
  68. All documents relating or referring to research of catalysts for 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 of your company or any member of any executive committee of your company or any other defendant in the present case.
  69. All documents relating or referring to whether or not to market a "safer" cigarette.
  70. 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.
  71. All documents relating or referring to representations to make or refrain from making in the advertising, marketing or promotion of "safer" cigarettes.
  72. All documents relating or referring to the Liggett XA, XA-5001, Tame, Bio Res or a Liggett "safer" cigarette.
  73. 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.
  74. All documents relating or referring to the National Cancer Institute work involving development of a 11saf or" cigarette.
  75. All documents relating or referring to the research, development or marketing of Eclipse and Premier cigarettes which were written by or shared 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.
  76. All patents and patent applications, whether filed in the United States or in another country, referring or relating to a "safer" cigarette.

  77. NICOTINE AND ADDICTION

  78. All documents relating or referring to the pharmacological or physiological effects of nicotine.
  79. All documents relating or referring to nicotine addiction, dependence, habituation, tolerance or withdrawal.
  80. All documents relating or referring to smoking cessation.
  81. All documents relating to the numbers or percentages of smokers who attempt to quit smoking -- successfully or unsuccessfully.
  82. All documents relating or referring to the determination of target levels of nicotine in cigarettes.
  83. All documents relating or referring to the effects on smokers of different levels of nicotine.
  84. 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.
  85. All documents relating or referring to nicotine analogues.
  86. All documents relating or referring to the monitoring, controlling, manipulating, altering, adjusting, restoring or adding of nicotine to tobacco or any part of the cigarette during any stop during the production of cigarettes, from the breading, growing and purchasing of tobacco to the manufacture of the final product.
  87. 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).
  88. All documents relating or referring to the effect of ammonia on nicotine.
  89. All documents relating or referring to acetaldehyde.
  90. All documents relating or referring to research, testing,test marketing or studies involving the relationship of nicotine to taste or flavor.
  91. All documents relating or referring to the relationship of nicotine levels to tar levels in cigarettes.
  92. All documents relating or referring to the development of a tobacco plant with altered levels -- increased or decreased - of nicotine.
  93. All documents relating or referring to blending tobacco to alter the nicotine content of tobacco in cigarettes.
  94. 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.
  95. All documents relating or referring to health hazards or potential health hazards of nicotine, including but not limited to cancer and cardiovascular disease.
  96. All documents relating or referring to the January 1972 conference in St. Martin on smoking (including all tape or video recordings)
  97. 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.
  98. All documents relating or referring to the effects of nicotine on persons age 18 or younger (or children, adolescents or young adults).

  99. YOUTH

  100. All documents relating or referring to the initiation of smoking or why persons begin smoking.
  101. 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).
  102. All documents relating or referring to smoking cessation efforts, successful or unsuccessful, among persons age 18 or under (or children, adolescents or young adults).
  103. 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.
  104. All documents relating or referring to focus groups, surveys, interviews, polls, studies, research or marketing plans involving smoking and persons age l8 or under (or children, adolescents or young adults).
  105. 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.
  106. 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).
  107. 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.
  108. All documents relating or referring to the placement of cigarette billboards near schools or playgrounds.
  109. All documents relating or referring to the effects of point-of-sale advertising on persons age is or younger (or children, adolescents or young adults).

  110. SURVEYS, MARKET RESEARCH AND ADVERTISING

  111. 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.
  112. 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.
  113. All documents relating or referring to the effectiveness of the warning labels on cigarettes.
  114. 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.
  115. All documents relating or referring to the effects of cigarette advertising.
  116. All documents relating or referring to the effects of anti-smoking advertising or the Fairness Doctrine on smoking.
  117. All documents relating or referring to the Roper Proposal.
  118. All documents relating or referring to research or polls by the Roper organization on smoking and health.
  119. 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 Tobacco ad "of cigarettes and science," as opposed to advertisements specific to particular brands of cigarettes.)
  120. 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).
  121. All documents summarizing the number or percentage of smokers who switch cigarette brands.
  122. 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 promotional work for cigarettes because of any issue involving smoking and health.
  123. 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.

  124. FTC TESTING

  125. All documents relating or referring to differences or. discrepancies between Federal Trade commission testing methods and actual intake of tar or nicotine by smokers.
  126. 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.
  127. 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.

  128. OTHER LITIGATION

  129. All transcripts of 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.
  130. 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.
  131. 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.
  132. 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
  133. All privilege logs produced by your company in any litigation, prior or pending, involving smoking and health.
  134. All document retention and nondestruct orders for all other litigation, prior or pending, involving smoking and health.

  135. ADDITIONAL-REQUESTS TO R.J. REYNOLDS

  136. All documents relating or referring to the Joe Camel advertising campaign, including reports, notes, memoranda, evaluations, marketing surveys, advertisements and promotions. This request includes, but is not limited to, all documents produced to the Federal Trade Commission as part of its investigation into the Joe Camel advertising campaign; provided, however, that any such documents produced to the Federal Trade Commission shall be produced in the present litigation in unredacted form (or redacted in accordance with the Case Management Order).
  137. All documents relating or referring to research at the laboratory nicknamed "the mouse house" in Winston-Salem, including but not limited to research performed at the lab and the decision to terminate research at the lab.
  138. All Brubaker Associates reports relating or referring to the "mouse house."
  139. All documents from the files of, authored by or sent to E.A. Darr which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.
  140. All documents from the files of, authored by or sent to Dr. Frank Colby which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.
  141. All documents from the files of, authored by or sent to Carl Eh1man which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.
  142. All documents from the files of, authored by or sent to A.H. Galloway which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.
  143. All documents from the files of, authored by or sent Bowman Gray which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes.
  144. All documents from the files of, authored by or sent to Murray Senkus which relate or refer to issues of smoking and health or advertising, marketing or promotion of cigarettes. Dated this 19th day of June 1995.‚Äč