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

  1. All annual reports to shareholders, from 1946 to the present.
  2. All documents relating or referring to the use of Chemosol in cigarettes or Chemosol cigarettes.
  3. All documents relating or referring to research by Hazelton on Chemosol, "safer" cigarettes or smoking and health.
  4. All documents relating or referring to U.S. Patents 3,258,015 and/or 3,356,094 or their foreign corresponding patents.
  5. All documents relating or referring to nicotine replacement treatments or devices, Including but not limited to nicotine patches, nicotine gum and nicotine aerosol.
  6. All documents relating or referring to projections or estimations of the impact on sales or profits of successful efforts at smoking cessation.
  7. 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 an well as expenditures broken out by departments, divisions or types of research and development, from 1946 to the present.
  8. 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.
  9. 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.
  10. All consent decrees or orders of the Federal Trade Commission regarding the advertising, marketing or promotion of cigarettes.
  11. All documents relating or referring to research on smoking and health, including but not limited to mouse-skin and inhalation tests and research on nitrosamines, conducted at Bioresearch facilities in Cambridge, Massachusetts.
  12. All documents relating or referring to research on smoking and health, including but not limited to mouse-skin and inhalation tests and research on nitrosamines, conducted at Bioresearch facilities in Montreal, Canada.‚Äč