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​​UNITED STATES’ FIRST REQUESTS FOR SUPPLEMENTATION OF DOCUMENT PRODUCTION TO ALL DEFENDANTS 

1. All documents created on or after January 1, 2001 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 that is covered by Report and Recommendation #10 and Order #74, or actual or contemplated legal judgment, on any Defendant’s financial condition, solvency, ability to pay such settlement or judgment, and/or any Defendant’s ability to continue as a going concern. 

2. All statements, press releases, advertisements, and promotions disseminated outside of your organization on or after January 1, 2001 relating to “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. 

4. All documents created on or after January 1, 2001 arising out of or relating to compliance with the terms and requirements of the MSA. 

5. All documents created on or after January 1, 2001 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 that is covered by Report and Recommendation #10 and Order #74, or actual or contemplated legal judgment, on any Defendant’s marketing, advertising, promotional or public relations practices, plans or activities. 

6. All documents created on or after January 1, 2001 relating to any analysis or research concerning whether any marketing, advertising, promotional or public relations practices will or will not appeal to youth, or will or will not initiate, maintain or increase the incidence of youth smoking. ​