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					Brown & Williamson

State of California (San Francisco) Request Number Designations and
Document Descriptions


The text of document requests, letter requests, and court orders from the
State of California (San Francisco) action is below. The documents
produced by Brown & Williamson in response to document requests and
letter requests were determined by court orders, applicable law, and
agreements with the plaintiffs in that case.

[YES] All documents obtained by you from the State of California, or any
office, officer, department, division, bureau, board, commission, or
other body or agency thereof, in response to any oral or written request
made by you, relating to the subject matter of this lawsuit, including,
without limitation, smoking and health, any anti-smoking law, any minor
access law, any cigarette vending machine law, any smoker education
program , any tobacco advertising law, smoking-related illness, the cost
of treating smoking-related illness, or cigarette smoking by minors or
young adults.

[YES] All documents obtained by you from the Senate or Assembly of the
State of California, or any committee, member, office, officer,
department, division, bureau, board, commission, or other body or agency
thereof, in response to any oral or written request made by you, relating
to the subject matter of this lawsuit, including, without limitation,
smoking and health, any anti-smoking law, any minor access law, any
cigarette vending machine law, any smoker education program, any tobacco
advertising law, smoking-related illness, the cost of treating smoking-
related illness, or cigarette smoking by minors or young adults.

[YES] All documents relating to any minor access law, including, without
limitation, any documents relating to the actual or potential effect of
any minor access law on the sale or consumption of cigarettes or other
tobacco products.

[YES] All documents relating to any cigarette vending machine law,
including, without limitation, any documents relating to the actual or
potential effect of any cigarette vending machine law on the sale or
consumption of cigarettes or other tobacco products.

[YES] All documents relating to any smoker education program, including,
without limitation, any documents relating to the actual or potential
effect of any smoker education program on the sale or consumption of
cigarettes or other tobacco products, and any documents relating to any
actual or contemplated response by you to any smoker education program or
the content thereof.

[YES] All documents relating to any tobacco advertising law, including,
without limitation, any documents relating to the actual or potential
effect of any tobacco advertising law on the sale or consumption of
cigarettes or other tobacco products.
[YES] All documents relating to the sale or consumption of cigarettes or
other tobacco products in the State of California.

[YES] For each year since 1952, all documents which summarize (or from
which it is possible to calculate) the gross revenue, gross profit, and
net profit received by you or by any other tobacco company from the sale
of cigarettes and other tobacco products in the State of California or
any part thereof, by product, brand name, and company.

[YES] For each year since 1952, all documents which summarize (or from
which it is possible to calculate) the annual advertising, marketing, and
promotional expenditures for cigarettes and other tobacco products by you
or by any other tobacco company in the State of California or any part
thereof, including without limitation, any such documents which include a
description of the type(s) of expenditure (e.g., television advertising,
free samples, etc.).

[YES] For each year since 1952, all documents which summarize your
cigarette advertising distributed or broadcast in California, including,
without limitation, any documents reflecting the publications or programs
in which you placed advertisements, the product advertised, and the
frequency with which the advertisement appeared in the publication or
broadcast.

[YES] For each year since 1952, all documents which summarize the market
share for cigarettes and other tobacco products held by you or by other
tobacco company in the State of California or any part thereof, both as
to dollar volume of sales and units sold, by product, brand, and company.

[YES] All documents relating to any estimate of the number of persons in
the State of California who smoke cigarettes and/or the age distribution
thereof, and/or any change in the number and/or age distribution of such
persons.

[YES] All documents relating to estimates of the number of persons in
California who have or who may develop smoking-related illnesses.

[YES] All documents relating to the market or potential market for a
safer cigarette in the state of California or any part thereof,
including, without limitation, all documents relating to the potential
effect of sales of a safer cigarette on sales of other cigarette brands
in California.

[YES] All documents relating to any sales or marketing research, or sales
or marketing plans, relating to the sale of cigarettes or other tobacco
products in California, including, without limitation, any documents
relating to focus group research conducted in California.

[YES] All documents relating to the identification of stores in
California in proximity to the teenage or young adult market for
cigarettes, including, without limitation, correspondence or other
communications with your distributors, retailers, ro sales
representatives.
[YES] All documents relating to the distribution by you of free
cigarettes in California including, without limitation, any documents
relating to the market segment targeted or reached by such free
distribution.

[YES] All documents relating to the promotion, marketing, sale, or
distribution by you of cigarette-related merchandise in California,
including identifying information about individuals who have requested,
purchased, ordered, or indicated an interest in such cigarette-related
merchandise.

[YES] All documents relating to the market for any cigarette-related
merchandise including, without limitation, any documents relating to any
actual or projected sales increases of cigarettes in California as a
result of the sale or distribution of cigarette-related merchandise.

[YES] All documents relating to any communication between you and any
public health officer relating to smoking and health, any anti-smoking
law, any minor access law, any cigarette vending machine law, any smoker
education program, any tobacco advertising law, smoking-related illness,
or a safer cigarette.

[YES] [As to defendant R.J. Reynolds Tobacco Company only.] For each year
since 1975, all documents relating to the following:

a. The number of Camel cigarettes sold in California;

b. The age distribution of purchasers of Camel cigarettes in California;

c. The market share held by Camel cigarettes in California;

d. The advertising, marketing, and promotional expenses for Camel
cigarettes in California; and

e. Your revenue, gross profit, and net profit from the sale of Camel
cigarettes in California.

[YES] [As to defendant Philip Morris, Inc. Only.] For each year since
1975, all documents relating to the following:

a. The number of Marlboro cigarettes sold in California;

b. The age distribution of purchasers of Marlboro cigarettes in
California;

c. The market-share held by Marlboro cigarettes in California;

d. The advertising, marketing, and promotional expenses for Marlboro
cigarettes in California; and

e. Your revenue, gross profit, and net profit from the sale of Marlboro
cigarettes in California.
[YES] All transcripts of depositions (and accompanying deposition
exhibits) taken in any other action brought by any state, county or city
seeking the recoupment of Medicaid or other public expenditures on
smoking-related illness, or seeking to impose penalties on you for
unfair, deceptive or unlawful trade practices or methods of competition,
and any of the following actions:

1. Craig Dunn and Phillip Wiley v. R.J. Reynolds, et al.. No. 18D01-9305-
CT-06 ( Delaware Superior court);

2. Haines v. Liggett group, et al., CV No. 84-678 (District New Jersey);

3. Rogers v. R.J. Reynolds, et al., 49 D02-9301-CT-0008 (Indiana circuit
Court Marion);

4. Philip Morris v. American Broadcasting Companies, No. LX-816-3
(Circuit Court Richmond, Virginia);

5. Cipollone v. Liggett Group, Inc. Et al., No. 84-67 (District New
Jersey);

6. Brown & Williamson Tobacco Corp. V. Walter Jacobson and CBS, Inc., No.
82- 2115 (7th Circuit). (Also produced in Florida v. American Tobacco
Co., No. 95- 1466AH (Florida Circuit Court, 15th Judicial Circuit);

7. Estate of Bur[1] Butler v. Philip Morris, Inc., et al., No. 94-5-53
(Circuit Court 2nd District, Jones County, Mississippi); and

8. Rames v. R.J. Reynolds Tobacco Co., No. 84-56 (AET) (District New
Jersey).

9. Mangini v. R.J. Reynolds Tobacco Co., No. 939359, San Francisco
Superior Court.

[YES] All documents that evidence, refer or relate to each of the
affirmative defenses raised in your amended answer.

[YES] All documents relating to, referring to, or constituting any
correspondence between you and the public plaintiffs concerning or
mentioning tobacco.

[YES] All documents relating to, referring to, or constituting any
communication between you and the public plaintiffs concerning or
mentioning tobacco.

[YES] All documents that refer to your advertising or promotions for
tobacco in California, including documents referring to the placement of
billboards or other advertisements in California, descriptions or
reproductions or such billboards, the dimensions of such advertisements,
the distance from the ground at which such advertisements were placed,
and dates such billboards were present at specified locations.
[YES] All documents that provide identifying information of agencies or
individuals hired to advertise tobacco or to develop your tobacco
marketing strategies in California.

[YES] All documents that provide identifying information of newspapers,
magazines or periodicals in which your tobacco has been advertised in
California, including circulation information, the target groups of such
publications, the dates on which your advertisements appeared in such
publications, and descriptions or reproductions of the advertisements
that appeared in such publications.

[YES] All documents that refer to or constitute mailing lists that have
been used at least one time in order to advertise tobacco in California.

[YES] All documents that refer to or constitute descriptions or
reproductions of advertisements that were sent through the U.S. Postal
Service to addresses in California.

[YES] All documents that refer to your efforts to market to minors in
California.

[YES] All documents that refer or relate to the youth market in
California, including your efforts to market to the youth or young adult
market in California, including any efforts to market to First Usual
Brand Young Adult Smokers ("FUBYAS").

[YES] All documents that refer to your efforts to advertise to a target
group in California, including but not limited to persons under 18 years
of age.

[YES] All documents that refer to any efforts by you to prevent or limit
sales, purchases, or possession of tobacco by minors in California,
including any documents that refer to or relate to the "We Card" program.

[YES] All documents that constitute or refer to any statement you made or
disseminated in California during the time period that:

(a) nicotine is not addictive;

(b) no proof or evidence exists that cigarette smoking causes lung
cancer, cardiovascular disease, or emphysema;

(c) no proof or evidence exists that cigarette smoking adversely affects
pregnancy;

(d) the products you manufacture are not injurious to health;

(e) you supported independent research on the health effects of tobacco
consumption; or

(f) you have a special responsibility to determine or disclose the health
effects of tobacco consumption.
[YES] All documents that constitute or refer to any statement you made or
disseminated in California during the time period that nicotine is
addictive.

[YES] All documents that refer to any violation of California Penal Code
§ 308 that were assessed against you or against any merchant of your
tobacco products during the time period.

[YES] All documents that refer or relate to any communications between
you and any other defendant in this lawsuit concerning smoking and
health, any anti-smoking law, any minor access law, any cigarette vending
machine law, any smoker educational program, any tobacco advertising law,
smoking-related illnesses, or a safer cigarette, including all documents
that refer to an agreement with any defendant in this case not to perform
research on tobacco or the health effects of tobacco.

[YES] All documents that refer to any communications between you and any
distributors or merchants of tobacco products, concerning smoking and
health, any anti-smoking law, any minor access law, any cigarette vending
machine law, any smoker education program, any tobacco advertising law,
smoking-related illness, the cost of treating smoking-related illness, or
cigarette smoking by minors or young adults.

[YES] Documents sufficient to show the terms and conditions of any bonus
or incentive program between you and distributors or merchants of tobacco
products, relating to the sale of tobacco in California.

[YES] All documents that refer or relate to financial interactions
between you and any distributors or merchants of tobacco products,
relating to any bonus or incentive program concerning the sale of tobacco
in California.

				
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