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,

and

BLUE CROSS AND BLUE SHIELD

OF MINNESOTA,

Plaintiffs, AFFIDAVIT OF SUSAN RICHARD NELSON

vs.

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

INSTITUTE, INC.,

Defendants.

-----------------------------------

STATE OF MINNESOTA )

) ss.

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

Notary Public

Dakota County, Minnesota

My commission expires Jan. 31, 2000

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