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to Minnesota STIC LibrarySTATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
CASE TYPE: Civil Other
The State of Minnesota FILE NO. C1-94-8565
By Hubert H. Humphrey, III,
Its Attorney General, and
Blue Cross and Blue Shield
of Minnesota,
Plaintiffs,
vs.
Philip Morris Incorporated,
R.J. Reynolds Tobacco Company,
Brown and Williamson Tobacco Corporation,
B.A.T. Industries P.L.C.,
Lorillard Tobacco Company,
The American Tobacco Company,
Liggett Group, Inc.,
The Council For Tobacco Research - U.S.A., Inc.,
and The Tobacco Institute,
Defendants.
AFFIDAVIT OF JONATHAN M. REDGRAVE
IN SUPPORT OF DEFENDANTS’ MEMORANDUM IN OPPOSITION TO
PLAINTIFFS’ MOTION TO COMPEL DISCOVERY CONCERNING
PRODUCT STANDARDS, ETC.
STATE OF MINNESOTA )
) ss.
COUNTY OF HENNEPIN )
Jonathan M. Redgrave, being first duly sworn, deposes and states as follows:
1. I am an attorney with Gray, Plant, Mooty, Mooty & Bennett, P.A. and am one of the attorneys representing defendant R. J. Reynolds Tobacco Company ("Reynolds") in the above-captioned litigation. This affidavit is being submitted in conjunction with the Defendants’ Memorandum In Opposition To Plaintiffs’ Motion To Compel Discovery Concerning Product Standards, Etc.
2. Attached as Exhibit 1 is the text of Plaintiffs’ First Set of Requests for Production of Documents, Request Nos. 28, 29, 37, 39, 40, 41, 42, 43, 44, 45, 46, 47, 61, 62, 63, 65, 78, 80, 82, 90 and the text of Plaintiffs’ Fourth Set of Requests for Production of Documents, Request No. 2.
3. Attached as Exhibit 2 is a true and correct copy of Jonathan Redgrave’s letter to Roberta Walburn dated September 5, 1996.
FURTHER YOUR AFFIANT SAYETH NOT.
/s/
Jonathan M. Redgrave
Subscribed and sworn to before me
this 30th day of September, 1996.
/s/
Notary Public
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