STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
Case Type: Other Civil
THE STATE OF MINNESOTA,
BY HUBERT H. HUMPHREY, III, COURT FILE NO. C1-94-8565
ITS ATTORNEY GENERAL,
BLUE CROSS AND BLUE SHIELD
Plaintiffs, AFFIDAVIT OF SUSAN RICHARD NELSON
PHILIP MORRIS INCORPORATED,
R.J. REYNOLDS TOBACCO COMPANY,
BROWN & 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
STATE OF MINNESOTA )
COUNTY OF HENNEPIN )
SUSAN RICHARD NELSON, being first duly sworn on oath, deposes and states as follows:
1. I am a partner at Robins, Kaplan, Miller & Ciresi and I am one of the attorneys representing the State of Minnesota and Blue Cross and Blue Shield of Minnesota in the above-captioned matter.
2. Exhibit 1 is a true and correct copy of excerpts from the Manual For Complex Litigation, Third, Federal Judicial Center (1995).
3. Exhibit 2 is a true and correct copy of excerpts from the Transcript of the Hearing before Judge Kenneth Fitzpatrick, Ramsey County District Court on November 7, 1995.
4. Exhibit 3 is a true and correct copy of the Memorandum in Support of Defendants' Proposed Case Management Order and Discovery Plan, Dianne Castano, et al. v. The American Tobacco Company, et al., United States District Court, Eastern District of Louisiana, dated April 3, 1995.
5. Exhibit 4 is true and correct copy of Amended Case Management Order No. 1, In Re: Minnesota Silicone (Breast) Implant Litigation, Judge G. Shumaker, dated December 10, 1992.
FURTHER YOUR AFFIANT SAYETH NOT.
/s/ Susan Richard Nelson
Susan Richard Nelson
SUBSCRIBED and sworn to
before me this 16th day
of February, 1996.
/s/ Trudy Lord Kanwischer
Dakota County, Minnesota
My commission expires Jan. 31, 2000
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