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​​UNITED STATES’ COMPREHENSIVE REQUESTS FOR PRODUCTION OF DOCUMENTS TO ALL DEFENDANTS

1. All documents arising out of or relating to any interest (whether ownership, proprietary, direct, indirect, beneficial, or otherwise), contractual relationship, or any other relationship you currently have or formerly had in any domestic or foreign entity involved in research relating to tobacco product development, cigarette design, cigarette manufacture, smoking and health, environmental tobacco smoke (“ETS”), nicotine, nicotine analogues, additives, addiction, smoking cessation, or marketing. 

2. All documents which depict all names, functions, or organizational structures and lines of reporting and/or authority for any office, department, division, group, or organization within your organization, including, but not limited to, formal or informal internal working groups, officers, employees, directors, staff positions and all predecessor or prior offices, departments, divisions, or organizations within your organization, from which documents responsive to any request for production in the Preliminary Requests of the United States or these Comprehensive Requests were written, received, reviewed, or located. 

4. All organizational charts depicting or describing your corporate structure, including parent companies, subsidiaries, corporate affiliates, predecessors, and successors, and any offices, departments, divisions, or organizations, including, but not limited to, formal or informal working groups, that are composed of employees or agents of more than one of the Defendants to this lawsuit or any parent companies, subsidiaries, corporate affiliates, predecessor, and successors that may have documents responsive to the Preliminary Requests of the United States or these Comprehensive Requests. 

5. All documents relating to bylaws and articles of incorporation, or functional equivalent thereof, for your organization and any entity in which you have an interest (whether ownership, proprietary, direct, indirect, beneficial, management, oversight, or otherwise) including, but not limited to, any changes to such bylaws and articles of incorporation. 

6. All telephone directories and all other documents relating to the current whereabouts of management and professional personnel employed by your organization from 1950 to the present in the areas of cigarette sales, cigarette marketing, diseases, cigarette research and development, consumer or behavioral psychology regarding smoking, sponsorship, public relations, lobbying, tobacco or cigarette component purchasing, cigarette manufacturing, tobacco product development, product research, biological and medical research concerning smoking and health or addiction, risk management, insurance, and, to the extent distinct from the above, any management and professional personnel providing advice concerning legal issues arising out of or relating to any of these areas. 

8. All documents relating to all forms of confidentiality, agreements utilized or contemplated to be utilized by any Defendant from 1950 to the present, including, but not limited to, agreements with employees, contractors, or any other Defendant(s), and all documents relating to violations, alleged violations, and enforcement of such agreements. 

9. All documents relating to meetings of the Board of Directors of your organization and/or Executive Committees of the Board of Directors relating to cigarette sales, cigarette marketing, diseases, cigarette research and development, consumer or behavioral psychology regarding smoking, sponsorship, public relations, lobbying, tobacco or cigarette component purchasing, cigarette manufacturing, tobacco product development,  product research, biological and medical research concerning smoking and health or addiction, risk management, insurance, and providing advice concerning legal issues arising out of or relating to any of these areas; including, but not limited to, all minutes from such meetings and all materials distributed or created at such meetings. 

13. All documents that identify all past and present managerial and professional personnel employed by Defendants responsible in any manner for the procurement of liability insurance (including, but not limited to, general comprehensive liability insurance, product liability insurance, health liability policies, health hazard liability policies) by Defendants, including, but not limited to, employees responsible for deciding whether Defendants should procure such insurance and for which potential risks or liabilities, including, but not limited to, documents identifying the time periods during which each such employee had this responsibility. 

16. All documents relating to or discussing: 

​a. whether to purchase insurance covering potential or actual liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products; 

b. whether insurance purchased by Defendants covers potential or actual liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products, including, but not limited to, documents discussing pollution exclusions; 

c. whether to self-insure against potential or actual liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products;  

d. whether a Defendant should or could ensure or do anything to ensure that it is able to pay for any liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products; 

e. how a Defendant should or could ensure or do anything to ensure that it is able to pay for any liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products; and 

f. how a Defendant should or could pay for any liabilities allegedly due to or arising directly or indirectly from smoking or tobacco products, including, but not limited to, raising the prices for cigarettes to pay for such liabilities. 

25. All documents relating to your financial condition, including, but not limited to, nonpublic financial statements, annual reports, Federal, State and foreign tax returns, reports, analyses, projections, budgets, and other material relating to your annual domestic cigarette sales revenues, market share, costs, and profits from 1940 to the present. 

27. All documents relating to reports, analyses, projections, budgets, and other material concerning the impact of the Master Settlement Agreement (“MSA”), and any other actual or contemplated settlement, or actual or contemplated legal judgment, on any Defendant’s organization’s financial condition, solvency, ability to pay such settlement or judgment, and/or your organization’s ability to continue as a going concern. 

36. All documents relating to joint venture activities between or among two or more Defendants relating to any of the following areas: cigarette sales, cigarette marketing, diseases, cigarette research and development, consumer or behavioral psychology regarding smoking, sponsorship, public relations, lobbying, tobacco or cigarette component purchasing, cigarette manufacturing, tobacco product development, product research, biological and medical research concerning smoking and health or addiction, risk management, insurance, and providing advice concerning legal issues arising out of or relating to any of these areas. 

37. All documents relating to the manufacturing of or the formula for each type of cigarette that is being or has been manufactured by any Defendant, including, but not limited to, the following:

​a. scientific analyses of the contents or design of cigarettes, including, but not limited to, documents relating to the nicotine content of the tobacco contained in the cigarettes, the delivery of nicotine by particular cigarette brands, methods of controlling or manipulating the content or delivery of nicotine, the health effects of particular cigarette constituents, additives used in cigarette manufacture, methods of altering the delivery of particular cigarette constituents, and any other known or suspected animal or human carcinogen, teratogen, or mutagen; 

b. suppliers or vendors of cigarette components or ingredients and the components or ingredients supplied by you, including, but not limited to, documents concerning the decision to purchase or otherwise procure tobacco cured to reduce tobacco-specific nitrosamines; 

c. efforts to alter or otherwise control or manipulate the content, combustion, pyrolysis, and/or chemical delivery of cigarettes; 

d. efforts to alter or otherwise control or manipulate the physiological effects of smoking through the manufacturing process; 

e. submission of information to governmental authorities regarding the contents, constituents, or ingredients of cigarettes, including such information for particular brands; and f. the tar content of cigarettes. 

38. All documents relating to research and development, design, manufacture, product development, and marketing efforts concerning alternatives to cigarettes or a less hazardous cigarette, including, but not limited to documents concerning: funding by you, in whole or in part; performance of any related work, whether performed by you or by an outside entity on your behalf; decisions whether to market, produce, or discontinue the development, production, or marketing of alternatives to cigarettes or a less hazardous cigarette; and economic analysis of the costs and benefits of marketing an alternative to cigarettes or a less hazardous cigarette. 
40. All documents relating to intellectual property protection sought or obtained in the United States or abroad for technology associated with cigarette manufacturing or design; the development of a less hazardous cigarette; and the development of low tar/low nicotine cigarettes, including, but not limited to, all patent applications filed and all supporting intellectual property documentation. 
42. All documents relating to research, development, and analysis of the production of tobacco, including, but not limited to, the use of pesticides, suckering control agents, and fertilizers. 
46. All documents relating to research, development, and use of additives in the cigarette manufacturing process, including, but not limited to, ammonia and Chemosol, and intellectual property protection sought or obtained for technology associated with the use of additives in cigarettes.
47. All documents relating to byproducts created, generated, or given off by the smoking or combustion of cigarettes. 
49. All documents relating to the purchase or licensing by one Defendant of another Defendant’s or third party’s products, services, or technology related to the manufacturing of cigarettes. 
50. All documents relating to the use of menthol in cigarettes, including, but not limited to, documents related to research concerning the constituents of menthol and the marketing of menthol cigarettes. 
51. Samples sufficient for at least three testings of each and every type of the following, for each and every current, proposed, and historical brand of your cigarettes, less hazardous cigarettes, and alternatives to cigarettes: 
a. raw tobacco, and any variation of the tobacco during each stage of the tobacco treatment process, including, but not limited to, Y-1 tobacco, Macon Expanded Tobacco, and any analogue, variation, or product from Y-1 or Macon Expanded Tobacco; 
b. all versions of reconstituted tobacco, and any variation of the tobacco during any stage of the tobacco treatment process; 
c. all additives presently used in the manufacture of any brand;  
d. any product, chemical, substance, or device used to affect the content of nicotine in the cigarette or the delivery of nicotine; 
e. any product, chemical, substance, or device used to affect flavor or other properties of the cigarette, including preservatives for packing, storage and delivery; 
f. filters; 
g. paper and any inks, dyes, or other substances used thereon. 
​53. All documents relating to communications (including, but not limited to, communications referenced in the appendix to the United States’ complaint) between you and other entities, including, but not limited to, marketing research agencies, advertising agencies, consumer research agencies, and syndicated data collectors, concerning the marketing of any of your tobacco products. 
54. All documents relating to industry or organization guidelines or codes relating to marketing of cigarettes, including, but not limited to, any voluntary advertising or sampling codes. 
55. All documents relating to point-of-sale practices and payments for display space for your or any Defendant’s tobacco products.
56. All documents relating to marketing strategy and planning for your or any Defendant’s tobacco products. 
57. All documents relating to research and other information concerning the effect of marketing generally or of particular marketing on decisions of individuals to begin to smoke, to continue to smoke, to refrain from quitting smoking, or to reduce the amount of their smoking. 
58. All documents relating to research or studies conducted to determine whether certain marketing techniques would not appeal to persons under the legal smoking age. 
59. All documents relating to mailings or other communications made to past, current, or prospective smokers. 
60. All documents relating to surveys, polls, interviews, focus groups, studies, or research involving the attitudes, understandings, or beliefs of smokers regarding the health risks, hazards, or addictiveness of cigarettes. 
61. All documents relating to demographics or characteristics of smokers or nonsmokers, the psychology of smokers, the reasons why people smoke, the reasons why people stop or reduce their amount of smoking, and the manner in which people react to information regarding the health risks or hazards or addictiveness of cigarettes. 
62. All documents discussing the potential or actual wording or content of domestic cigarette warning labels. 
63. All documents discussing the potential or actual wording or content of foreign cigarette warning labels. 
64. All documents relating to the impact, effectiveness, or perception of warning labels by smokers and nonsmokers, and reliance on such warning labels by smokers and nonsmokers.  
65. All documents relating to the marketing of cigarettes on television, radio, and the Internet, and in motion pictures and films. 
66. All statements, press releases, advertisements, and promotions disseminated outside of your organization, relating to smoking and health or ETS; scientific or behavioral research concerning the health effects of smoking or ETS, smoking cessation, addiction to cigarettes, their ingredients or constituents; cigarette design; development of a less hazardous cigarette or alternatives to cigarettes currently sold; marketing of tobacco products; youth smoking; “global settlements” of smoking and health or cost recovery lawsuits or legislative proposals related to smoking and health, including, but not limited to, the MSA and the settlements with individual States; and the funding or participation in joint activities with any other Defendant, person or entity concerning any of the above issues; and all documents relating to those statements, press releases, advertisements, and promotions (including, but not limited to, statements, press releases, and advertisements referenced in the appendix to the United States’ complaint). 
67. All documents relating to the impact and effect of cigarette marketing on consumer preferences for brands of cigarettes, including, but not limited to, documents concerning the number or percentage of smokers who switch cigarette brands. 
71. All documents relating to the placement of cigarette advertisements, promotional materials, or marketing materials at sporting or entertainment events, including, but not limited to, documents from January 1, 1971, to the present relating to the placement of such advertisements, promotional materials, or marketing materials so that when events or programs at such locations were televised, these advertisements, promotional or marketing materials similarly were televised. 
74. All documents relating to the formation of any cigarette, tobacco or nicotine product marketing policies or practices that any Defendant has had in effect since 1950. 
75. All documents relating to the costs of, and expenditures on, cigarette, tobacco, or nicotine product marketing, including, but not limited to, figures for particular campaigns and particular brands, itemized on an annual basis, if available. 
77. All documents relating to all communications with your employees concerning smoking and health, including, but not limited to, internal newsletters and notifications. 
79. All documents relating to formal or informal communications between and among any director, officer, employee, representative, or agent of your organization and any other Defendant, including, but not limited to, correspondence (including, but not limited to, correspondence referenced in the appendix to the United States’ complaint), meeting minutes, telephone notes, and any other statements concerning smoking and health or ETS; scientific or behavioral research concerning the health effects of smoking or ETS, smoking cessation, addiction to cigarettes, their ingredients or constituents; cigarette design; development of a less hazardous cigarette or alternatives to cigarettes currently sold; marketing of tobacco products; youth smoking; “global settlements” of smoking and health or cost recovery lawsuits or legislative proposals related to smoking and health, including, but not limited to, the MSA and the settlements with individual States; and the funding or participation in joint activities with any other Defendant, person or entity concerning any of the above issues.  
80. All documents relating to or discussing: 
a. whether smoking is a cause of disease or risk factor associated with disease, including, but not limited to, lung cancer, cardiovascular diseases, chronic obstructive pulmonary disease (“COPD”), emphysema, and asthma; 
b. whether ETS is a cause of or risk factor associated with disease, including, but not limited to, lung cancer, cardiovascular diseases, COPD, emphysema, and asthma; and 
c. whether smoking is addictive, habituating, or dependence-producing. 
81. All documents relating to information posted on your Internet document websites (including, but not limited to, website information referenced in the appendix to the United States’ complaint), from the inception of the site to the present, concerning smoking and health; health warnings; addiction; levels of tar and nicotine; youth smoking; ETS; smoking cessation; and marketing. 
85. All documents relating to the Surgeon General’s reports and to any other governmental or non-governmental reports that concern smoking and health. 
86. All documents relating to, or arising out of, communications with the Office of the Surgeon General, including, but not limited to, correspondence with Leroy E. Burney, S. Paul Ehrlich, Jr., M. Joycelyn Elders, C. Everett Koop, Antonia C. Novello, Julius B. Richmond, David Satcher, Jesse L. Steinfeld, William H. Stewart, Luther Terry, and any other current or former Surgeon General related to tobacco, smoking and health, youth smoking, or addiction. 
87. All documents relating to the Federal Trade Commission’s (“FTC”) annual reports to Congress relating to current practices and methods of cigarette marketing. 88. All documents relating to publicizing information (including via the Internet) concerning the causal relationship between smoking and disease, the addictiveness of smoking, or decisions not to publish or publicize such information. 
89. All documents relating to publicizing information (including via the Internet) concerning smoker “compensation” and the actual tar and nicotine delivery of low tar/low nicotine cigarettes or decisions not to publish or publicize such information. 
90. All documents relating to including or removing notice or warning information on cigarette packaging that is not required by law to be placed on such packaging. 
92. All documents relating to the establishment, perpetuation, or change in any Defendant’s public position concerning the relationship between smoking and disease, and ETS and disease. 
93. All documents relating to the establishment, perpetuation, or change in any Defendant’s public position concerning the relationship between smoking and addiction. 
102. All documents relating to general public (i.e., non-governmental) or consumer communications concerning the health effects, addictiveness, or marketing of cigarettes, including, but not limited to, your organization’s responses to any letters or inquiries, including, but not limited to, correspondence referenced in the appendix to the United States’ complaint.  
103. All documents relating to research or studies concerning smoking and health, ETS, addiction, or product development, conducted by individuals, organizations, or other entities within the United States undertaken by or on behalf of any Defendant, and all documents related to, the dissemination (or restrictions on dissemination) within or outside, to or from, the United States of these studies, research, or research findings, including, but not limited to, research funded in whole or in part by CTR, TI, or the Scientific Advisory Board (“SAB”). 
109. All documents relating to testing undertaken by or on behalf of any Defendant relating to the tar or nicotine content of particular cigarettes. 
111. All documents relating to any survey of smoking habits performed by or on behalf of any Defendant. 112. All documents relating to a determination or decision of whether or not to conduct research involving smoking and health, including, but not limited to, all documents relating to research that was discontinued or suppressed because the expected, preliminary or final results were inconsistent with or otherwise contradicted litigation or public relations positions taken by or on behalf of any Defendant, individually or jointly, relating to issues of smoking and health, ETS, or the addictiveness of cigarettes. 
115. All documents relating to the retention or storage of research and other business documents related to issues of smoking and health, as well as destruction, removal, transfer, invalidation, or disposition of such documents. 
116. All documents relating to any Defendant’s involvement in the destruction, dismantling, or removal of research facilities or equipment used to conduct smoking and health or tobacco-related research, and all documents relating to the destruction of any results, Conclusions, or raw data of such research. 
117. All documents relating to communications, agreements, directives, discussions, or recommendations made by or with any other Defendant or any other entity to terminate or not undertake research on smoking and health or to develop or market, or not develop, produce, or market, a less hazardous cigarette. 
​118. All documents relating to the annual expenditures for research and development by any Defendant, from 1950 to the present, on matters concerning smoking and health, ETS, and addiction, including, but not limited to, budgets depicting total expenditures on research and development as well as expenditures itemized by departments, divisions, or types of research and development. 
119. All documents relating to annual expenditures for research and development underwritten or funded by or through any Defendant, and performed or conducted by another organization or a person outside of your organization, concerning tobacco, smoking and health, youth smoking, ETS, or addiction from 1950 to the present. 
123. All documents relating to methods or processes by which any smoking machine measures tar and/or nicotine, including, but not limited to, all documents related to the accuracy of such measurements.  
124. All documents relating to the addicting or habituating properties of cigarettes, or any components, ingredients, or constituents of cigarettes, or to the tendency of cigarettes to cause addiction, including, but not limited to, the following: 
​a. the effect of cigarettes, or any components, ingredients, or constituents of cigarettes, upon the brain; 
b. the physiological effects of smoking or any components, ingredients, or constituents of cigarettes; 
c. the psychological effects of smoking or any components, ingredients, or constituents of cigarettes; and 
d. alteration, control, or manipulation of cigarette constituents. 
130. All documents relating to the monitoring, controlling, manipulating, altering, adjusting, restoring or adding of nicotine to tobacco or any part of the cigarette during any stage of the manufacturing process, including, but not limited to, the breeding (including genetic manipulation), growing, blending, and purchasing of tobacco all the way through to the manufacture of the final product. 
139. All documents relating to anti-smoking campaigns that were targeted at age groups under the age of 25, including all correspondence between any Defendant and any outside public relations, advertising, or marketing person, agency, or firm. 
140. All documents relating to smoking by persons under the age of 25, including, but not limited to, the following: 
​a. Marketing to young adults, younger adults, youth, young smokers, young adult smokers, beginning smokers, starter smokers, replacement smokers, children, or otherwise to those who are younger than 25 years of age, including, but not limited to, statements referenced in the appendix to the United States’ complaint; 
b. Anti-smoking activities, initiatives, or campaigns initiated by you or any of the Defendants, individually or jointly with any other person or entity, that were targeted at age groups under the age of 25; and 
c. Publishing or otherwise publicizing information (including via the Internet) concerning smoking by persons younger than 25 years of age. 
145. All documents, including, but not limited to, marketing reports and plans, discussing product research, product line extensions, media selection, advertising messages or budgets, that implemented, or were prepared for the purpose of implementing, any results of cigarette-related consumer research regarding smoking and health, smoking by persons younger than 25 years of age, certain ethnic groups, and/or women. 
150. All minutes of meetings, and all materials distributed or created at such meetings, between any executives of any Defendant, and marketing research agencies, advertising agencies, or syndicated data collectors. 
158. All documents relating to chocolate cigarettes, candy cigarettes, candy stix, and/or other food products sold in packaging, including, but not limited to, illustrations, color schemes, and simulated tax stamps, resembling cigarette packaging. 
159. All documents relating to, or that discuss or correspond with any of the following: World Candies, New England Confectionery, psychologist Dr. Howard Kassinove, and/or the  National Automatic Merchandising Association Special Committee on Cigarette Vending. 
160. All documents relating to the distribution of free cigarettes as either a premium for the purchase of cigarettes or as a promotional giveaway, including but not limited to, documents from which the annual number of cigarettes distributed in such a manner can be derived and the location of such distribution. 
161. All documents relating to trademark infringement or alleged trademark infringement of your tobacco products. 
163. All documents relating to the past, current, or projected health care costs associated with smoking or ETS, including, but not limited to, the amount of money, expended by any public health care systems, plans, programs, or entities (including, but not limited to, the Medicare System; the health programs administered by the Veterans Health Administration, the federal military branches, or the Indian Health Service; the Federal Employees Health Benefits Program; and State Medicaid Programs) to pay for costs possibly, actually, or claimed to be associated with the effect of smoking on the health of smokers and nonsmokers. 
165. All documents discussing or relating to the research published as Manning, Keeler, Newhouse, Sloss and Wasserman, “The Taxes of Sin, Do Smokers and Drinkers Pay Their Way?” JAMA 261:1604-09 (1989). 166. All documents relating to any reports, studies, analyses, articles, comments, or opinions concerning the external and internal costs or lifetime costs of smoking; and all documents  discussing or relating to any reports, studies, analyses, articles, comments, or opinions concerning any alleged cost savings due to the effects of smoking on morbidity or mortality or concerning other monies (including, but not limited to, taxes on cigarettes) that you or any Defendant contends offset/cover the costs of smoking to public or private health care systems, plans, and programs. 
172. All materials from any public relations or media consultants including, but not limited to, Hill & Knowlton, Tiderock Corp., Ted Bates & Co., Ruder & Finn, and Intermedia, related to smoking, tobacco, or smoking and health. 
174. All documents relating to any Defendant’s membership in, involvement with, communications with, or participation in domestic or foreign tobacco or smoking and health trade associations or tobacco industry groups or scientific conferences or meetings, including, but not limited to, the Tobacco Research Council, the Tobacco Advisory Committee, the Tobacco Advisory Council, Tobacco Chemists Research Conference, Tobacco Manufacturers Association, CORESTA (Centre de Cooperation pour les Recherches Scientifiques Relatives au Tabac, also known as The Centre for Cooperation in Scientific Research relative to Tobacco), INFOTAB (International Tobacco Information Centre), ICOSI (International Committee on Smoking Issues), Verband, International Tobacco Growers Association, International Life Sciences Institute, Middle East Tobacco Association, including all predecessors, successors, affiliates, and subgroups. 
175. An documents relating to the membership, involvement, communications with, or participation by any director, officer, employee, representative, corporate affiliate, or agent of any Defendant (other than CTR or T1), in CTR or TI, or any other tobacco-related or smoking and health-related entity in which more than one Defendant has participated, including, but not limited to, identification of all committees, subcommittees, and other related structures in which Defendants participated in these organizations. 
179. All documents relating to: 
​a. the manner and amounts in which any Defendant, other than CTR or TI, funded or participated in CTR or TI or any of their committees, research, or other activities; 
b. CTR’s SAB, including information concerning each Defendant’s, other than CTR’s or TI’s, financial contribution to the SAB, direct or otherwise; 
c. CTR special projects, special accounts, institutional research, or other CTR grants or contract research, including, but not limited to: correspondence between or among any Defendants, including correspondence referenced in the appendix to the United States’ complaint; and publications resulting from and each Defendant’s, other than CTR’s or TI’s, contributions to any such project, account, grant or contract; 
d. the process for applying for grants or contract research funds from the CTR, including, but not limited to, special projects and special accounts funds; the screening or review of these applications or requests; the approval or disapproval of these requests; and the process of funding researchers to conduct special projects, special account or other industry sponsored research;  e. the process for applying for grants or contract research funds from the SAB; the screening or review of these applications or requests; the approval or disapproval of these requests; and the publications resulting from the award of grants by SAB;
f. grant and contract payment schedules, including, but not limited to, research funded through the SAB, CTR, special projects, or special accounts funds; 
g. the purpose of or use for CTR special accounts, special projects, central files, and any other research programs conducted through CTR; 
h. the Literature Retrieval Division, including its creation, reorganizations, removal from CTR, and transfer of its functions to one or more other entities; 
i. indices of the documents maintained by the Literature Retrieval Division (and its predecessors and successors), including, but not limited to, abstracts of scientific articles prepared or generated by any Defendant or by any person or entity working on behalf of any Defendant; j. the Tobacco Institute Testing Lab (“TITL”); and 
k. any entity that any Defendant funds or in which it otherwise participates that currently or in the last 10 years has conducted activities formerly conducted by CTR or TI. 
181. All documents relating to, or arising out of, communications with any current or former Member of the SAB including, but not limited to: Leo Abood, Howard B. Andervont, Barry G.W. Amason, Richard J. Bing, Roswell K. Boutwell, Drummond H. Bowden, Michael J. Brennan, McKeen Cattell, Julius H. Comroe, Jr., John E. Craighead, Carlo M. Croce, Raymond L. Erikson, Joseph D. Feldman, William U. Gardner, Gordon N. Gill, James F. Glenn, Peter M. Howley, Robert J. Huebner, Jeffrey Idle, Leon C. Jacobson, -22- W.K. Joklik, Manfred Kamovsky, Alfred Knudson, Paul Kotin, Averill A. Liebow, Clayton G. Loosli, Henry T. Lynch, Kenneth Merrill Lynch, Harmon C. McAllister, Hugh O. McDevitt, Hans Meier, G. Barry Pierce, Stanley P. Reimann, William F. Reinhoff, Jr., David D. Sabatini, Gordon H. Sato, Judith Swain, Peter Vogt, Lee Wattenberg, Edwin B. Wilson, and John P. Wyatt. 
182. All documents relating to Shook, Hardy, & Bacon-administered special accounts and special funds, including, but not limited to, expert witness funds, and all other special accounts and special funds administered by any entity. 
184. All documents relating to any CTR funding of research involving the Kaiser-Permanente Health Care Plan, including results of that research. 
185. All documents relating to the compendium of scientific research regarding smoking and nicotine prepared by Larson, Haag, and Silvette. 189. All documents relating to the 1978 Roper Survey Report, produced by The Roper Organization, Inc. for the Tobacco Institute. 
194. All documents relating to meetings of TI’s Committee of Counsel, TI’s Communications Committee, or TI’s Executive Committee, including, but not limited to: 
​a. minutes from these meetings; 
b. notes of persons who attended these meetings; c. documents distributed at these meetings; d. documents created as a result of these meetings. -
196. All documents relating to the Industry Research Working Group; Industry Research Support Planning Committee; Research Liaison Committee; Industry Research Committee; Industry Technical Committee; the Less Hazardous Cigarette Working Group; or any other industry research committee, including, but not limited to, notes and minutes of meetings of these committees. 197. All documents relating to industry committees of counsel, Ad Hoc Committees, Tobacco Strategy Review Teams, Cigarette Advertising Code, Inc., or any other committee involved in strategy or litigation including, but not limited to, notes and minutes from meetings of these committees. 
198. All documents relating to the Tobacco and Health Research Program at Harvard University or the Harvard Project, including, but not limited to, documents relating to the creation, funding, human and animal research, transfer, and discontinuance of the program, as well as documents relating to Dr. Gary Huber, Dr. Henry C. Meadows, Charlesgate, Charlesgate West, and possible transfer of any research to Beth Israel Hospital or Mt. Auburn Hospital. 200. All documents relating to any alleged partnership or cooperation of the United States Government with any Defendant or the tobacco industry as a whole, including, but not limited to, all documents relating to, discussing, or supporting statements made by Philip Morris attorney Greg Little on September 22, 1999, at a press conference discussing an alleged partnership between the Federal government and the tobacco industry.  
201. All documents relating to the actual or purported involvement of the Federal government in smoking and health issues, including, but not limited to, copies of TI’s “Federal Government Involvement in the Smoking Controversy.” 
202. All documents relating to, or arising out of communications concerning smoking and health or tobacco products, or any other issue identified in the Preliminary Requests of the United States or these Comprehensive Requests, with any of the following individuals: Neil Benowitz, H.R. Bentley, Donald Capra, Michael Cummings, Arthur Eisenberg, D.G. Felton, Donald Ford, Robert Gertenbach, James Glenn, Paul Hahn, Timothy Hartnett, George Hashim, Rob Hockett, Freddy Homburger, W.T. Hoyt, Cecile Leuchtenberger, Rudolf Leuchtenberger, Vincent Lisanti, Clarence Cook Little, Ronald Lukas, Harmon McAllister, Suzanne Oparil, Lorraine Pollice, W.W. Reid, Fred Schultz, Carl Seltzer, John Slade, Sheldon Sommers, Geoffrey Todd, Bea Van den Berg, and Leonard Zahn. 
215. All documents arising out of or relating to trial or deposition testimony or other information provided by your organization, officers, directors, employees, expert witnesses, or consultants, or other representatives, including, but not limited to, transcripts and videotapes of such testimony and all exhibits to such testimony, in all smoking and health, addiction, ETS, and/or cost recovery lawsuits, including lawsuits in the United States and any other country, filed from 1950 to the present. 
220. All documents arising out of or relating to testimony (including, but not limited to, testimony referenced in the appendix to the United States’ complaint) or other information concerning any issues identified in the Preliminary Requests of the United  States, these Comprehensive Requests, and/or raised in this case, provided to any legislative, administrative, regulatory or international body in the United States or foreign country, from 1950 to the present, including, but not limited to, transcripts and videotapes of such testimony and all exhibits thereto, and all correspondence and communications between you or any Defendant and any Member or Committee of the United States Congress or any other legislative or international body in the United States and any other country. 221. All logs or indices of privileged documents that were created in connection with any smoking and health, addiction, ETS, or cost recovery litigation or created in connection with any other legal, regulatory, or legislative proceedings within the United States or any other country. 
222. All written discovery, in whatever form any jurisdiction or country recognizes, served upon your organization in other prior or pending litigation, within or outside the United States, concerning issues relating to smoking and health, addiction, and ETS, including, but not limited to, interrogatories, requests for production of documents and things, and requests for admissions; all of your answers, responses, and objections to such written discovery; all motions to compel, motions for protective orders, or motions to quash related to such written discovery; document preservation or non-destruct orders issued by judicial authorities; and all documents produced by your organization in response to such written discovery.  
226. All joint defense agreements or understandings with any other Defendant or past or present corporate affiliate of any other Defendant, and all documents relating to joint defense agreements or understandings. 
227. All documents relating to any Defendant’s compliance with their settlements of smoking and health-related litigation with the States, including the MSA and individual State settlements, including, but not limited to: a. economic effects of these settlements, including, but not limited to, the effects on sales of cigarettes, effects on pricing of cigarettes, and other business or financial impacts; b. modifications, alterations, or changes to marketing strategy or practices as a result of these settlements; and c. compliance by any Defendant with these settlements, including, but not limited to, any failure or alleged failure of any Defendant to comply with these settlements. 
228. All documents relating to any proposed or actual settlement of any non-individual claim (that is any claim against any Defendant by anyone other than a single, individual smoker) concerning tobacco, smoking and health, youth smoking, or addiction, or any proposed or actual legislative initiative concerning settlement of any such suit, excluding the MSA or settlement with individual States, including, but not limited to, analysis, discussion, or comment upon complying with proposed settlement agreements or legislative initiatives and analysis, discussion, or comment upon the effect on your organization’s business of compliance with the proposed settlement’s terms.  
230. All documents (including all communications) relating to Liggett’s statements acknowledging a causal relationship between smoking and serious disease and that cigarettes are addictive. 
232. All documents relating to, or arising out of communications concerning smoking and health or tobacco products, or any other issue identified in the Preliminary Requests of the United States or these Comprehensive Requests, with any of the following United States Government employees, officials or appointees (before, during, or after their governmental tenure): Peter Bourne, David Burns, Joseph Califano, Wilbur J. Cohen, Jerome Cornfield, Ronald Davis, Jack Henningfield, Daniel Horn, William Hueper, David Kessler, Joanne Luoto, John Pinney, Donald Shopland, or Judith Wilkenfeld.
233. All documents relating to the Tobacco Working Group (“TWG”), its predecessors, its successors, and all subgroups of the TWG and its predecessors and successors, including, but not limited to, your organization’s participation in the TWG, the decision of whether and how to participate or to terminate your organization’s participation in the TWG, your organization’s contribution of materials and resources to the TWG, including experimental cigarettes, presentation of research at TWG meetings, or your comments on TWG reports. 
234. All documents relating to the Joint Committee on Tobacco and Health. 
235. All documents relating to, or arising out of, communications with any member of, or person associated with, the TWG including, but not limited to: Carl G. Baker, James Chaplin, Kenneth Endicott, Joseph F. Fraumeni, Gio Gori, Harry W. Hays, Dietrich Hoffmann, Gardner C. McMillan, Thomas B. Owen, Mearl F. Stanton, or T.C. Tso.  
239. All documents relating to all smoking and tobacco-related proposals, statements, policies, positions, executive orders, programs, initiatives, and activities of any President of the United States during the term or terms of his office as well as the offices, councils, or other individuals and units of the Executive Office of the President. 
240. All documents relating to communications within your organization, between and among some or all Defendants and between any Defendant and the Executive Branch, Legislative Branch, or any independent agency, commission, or authority of the United States Government, including, but not limited to, correspondence, press releases, speeches, public statements, meeting minutes, telephone notes, and any other statements concerning proposed or enacted legislation related to smoking and health; tobacco; the manufacture, sale, taxation, labeling, packaging, marketing, importation, and exportation of cigarettes, including, but not limited to: the Federal Cigarette Labeling and Advertising Act of 1965; the Public Health Cigarette Smoking Act of 1969; the Health Protection Tax Act of 1977; the National Disease Prevention and Health Promotion Act of 1978; the Alcohol and Drug Abuse Amendments of 1983; the Comprehensive Smoking Education Act of 1984; the Alcohol, Drug Abuse, and Mental Health Administration Reorganization Act of 1992; and National Tobacco Policy and Youth Smoking Reduction Act of 1997. 
241. All documents relating to communications within your organization, between and among some or all Defendants and between any Defendant and the Executive Branch, Legislative Branch, or any independent agency, commission, or authority of the United States Government, including, but not limited to, correspondence, press releases, speeches, public statements, meeting minutes, telephone notes, and any other statements  concerning proposed or adopted regulations related to smoking and health; tobacco; the manufacture, sale, taxation, labeling, packaging, marketing of cigarettes, including, but not limited to, the Federal Communication Commission’s (“FCC”) consideration and implementation of a ban on television and radio advertising, the FTC’s regulation of tar and nicotine levels, and the Food and Drug Administration’s regulation of tobacco products. 
245. All documents relating to proposals to terminate the tobacco price support program, tobacco and cigarette export subsidies, and government inspection and grading of tobacco. 
247. All documents relating to a ban on using Department of Agriculture funds to carry out research related to the production, processing, or marketing of tobacco and tobacco products. 
249. All documents relating to research conducted by or at the request of the Executive Branch, Legislative Branch, or any independent agency, commission, or authority of the United States Government that relates to smoking, the health effects of smoking, a less hazardous cigarette, leaf blending, tobacco curing, manipulation of tar and nicotine levels, genetic manipulation (including breeding, protoplast fusion, and genetic engineering), and any other tobacco plant or tobacco product research and development, including, but not limited to, research conducted by or at the request of the Department of Agriculture, the Department of Defense (“DOD”), the Department of Veterans Affairs, the Department of Health and Human Services, the Bureau of Alcohol, Tobacco, and Firearms, and the FTC. 
251. All documents relating to research concerning tobacco, cigarettes, and smoking and health conducted at the Inhalation Toxicology Research Institute, the Oak Ridge National Laboratories, the Battelle Pacific Northwest Labs, the Sandia National Laboratory, and any other laboratory or testing facility affiliated with the Department of Energy. 
252. All documents relating to the application of the FCC’s “fairness doctrine” to cigarette advertising, dissemination of anti-smoking messages pursuant to this doctrine, and their effect. 
253. All documents relating to smoking and tobacco-related research, studies, proposals, publications, reports, regulations, programs, initiatives, and activities of the Department of Health and Human Services. 254. All documents relating to the Interagency Committee on Smoking and Health, its predecessors, its successors, and all sub-units of the Committee, its predecessors, or successors. 
258. All documents relating to the Bureau of Prisons (“BOP”) concerning the provision of cigarettes to BOP inmates, the sale of cigarettes at BOP facilities or by BOP; the pricing and taxation of cigarettes for sale at BOP facilities or by BOP; the consumption of cigarettes by BOP inmates; the packaging and labeling of cigarettes for sale at BOP facilities or by BOP, or provided to BOP inmates; the marketing of cigarettes at BOP facilities; and the production of tobacco or cigarettes at BOP facilities or by BOP. 
259. All documents relating to the provision of cigarettes to DOD personnel and dependents; the sale of cigarettes at DOD facilities or by DOD; the pricing and taxation of cigarettes for sale at DOD facilities or by DOD; the consumption of cigarettes by DOD personnel and dependents; the use of cigarettes in areas subject to DOD authority; the packaging and labeling of cigarettes for sale at DOD facilities or by DOD, or provided to DOD personnel; the marketing of cigarettes at DOD facilities; and the export or import of tobacco products to DOD facilities. 
260. All surveys, informal or formal, of the cigarette purchase and smoking practices of military personnel in the United States, and all documents relating to such surveys. 
262. All documents relating to proposals or activities of the Department of Labor to regulate cigarette smoke or indoor air quality. 
263. All documents relating to activities of or communications with the Environmental Protection Agency concerning ETS. 
264. All documents relating to or arising out of reports, articles, publications, or meetings of the American Health Foundation, or any predecessor, successor, or sub-group thereof, related to tobacco, smoking and health, youth smoking, or addiction. 
265. All documents relating to, discussing, or concerning domestic and foreign tobacco control and/or tobacco research activities of third parties, including, but not limited to, those of the World Health Organization and the United Nations (“UN”), and the UN Framework Convention on Tobacco. 
269. All documents relating to any investigation of cigarette advertising, promotion, or marketing by any regulatory or law enforcement authority, including, but not limited to, the FTC. -32- 271. All documents relating to anti-smoking or anti-tobacco groups or associations. 
272. All documents relating to the International Agency for Research on Cancer (“IARC”).
273. All documents relating to the American Medical Association. 
274. All documents relating to Operation Berkshire.