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24 :
Rave you ever inquired as to whether or
not that's correct?
3 A. Not that : re=e=ber.
Does BATUS or 3row= & W1l1!a=sc= have
any insurance for tobacco products liability?
A. No.
q. Does 3ATUS a r 3rown & Williamson have
a any agreements with any other entities to share
9 pateztlal liabilities arising out of tobacco
!a products liability 9*alts7
11 A. Not that Z'z aware of.
!2 Q. Does BATUS or Brown & Willia=son have
13 any reserves am its baole to cover potential
losses
14 from tobacco products !'-ability suits?
is A. no.
Is Q. Have you done any studies of the
17
potential magnitude of losses which could acc-zr
13 :ran tobacco products liability suits?
19 A. Not that Z'= aware of.
20 Do you know whether Srown & Williazzon
21. ;articlpate3 In an agreement between S.A.T.'s
22 tobacco co=panies to share the cost of research
23 -'=to the Zink between smoking and various
diseases
24 based on the volume of tur=-over a! each of the
EXHIE31T 9
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244
3-A.T. tobacco companies?
No.
Eave you ever i=q--Ired as to whether or
4 not Brown Williamson is a participant in such am
5 agreement?
6 No.
Now, this exhibit that has been marked
as Exhibit 5001, "Facts about Smoking.' you've
seen
this brachare a mr.=ber a! times previously,
ha7e=lt
:3 yar., Mr. Aramtsen?
:1. A. Yes.
:2 Mr. Smith, on yo%Lr last qmestion, Z
13
would just like to clarify that. Z= the past,
14 have been aware that there has been some
alloca-,ion
of costs fro= B.A.T. for research to Brown &
Williamson. but I dan't know what the nature a!
that research was.
Did you ever inquire?
No.
20 So you don't know whether that research
21. related to links between smoking and dtseasea
or
22 =at?
23 A. That's correct.
24 Q. Looking at Exhibit 5001, Mr. Are=*tser..
XXTIPIA and c4uo~-~ x, ff,=
0 (372J782-8087
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2-
I is it BAT=S's position that it would tot permit
2 Taz=ers or any a! tt3 affiliated co=pa=les to
3 CC=tiM%Z* the diStributiOr. of th13 broch-are
after a=
A acqz1s!t!c= by SATZS?
5 A. Well, it's our position, Mr. Smith, that
6 we would sit dowm with ?ar=ers management and
7 review this brochure with them.
And what if ?ar=ers management insisted
9 on com%imulmq to distribute the brochure?
10 Would you allow.them to do so?
11 A. AS WO have testified earlier, we would
12 not.
13 And that's
TEE ---T-AR:XG OFFICER: Would you identify this
15 exhibit for %he record?
MR. SM:TE: I'= sorry. It is a document
.7 entitled ".--acts about Smoking," produced by
-Farmers
la Now World :!!~ Insurance Company.
19 :ET ETARING CF?ZCZ.R: Thank you. And it's
20 exhibit =z-ber what?
21 MR. SK:73: 5001, your Romer.
22 T17- 3r-ARZXG O?rICZ-R: Thank you.
23 3Y MR. SM::V-:
24 And you disagreed, I take it. Mr.
o rii2)782-8087
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24
1 Aremtze=, with the accuracy of some a! the
!actual
2 s-.ate=e=ts ca=ta!=id in this doc,--=ent?
3 A. Well, as :1ve previously testified, Z1=
4 not a scientist, and Z really can't say that Z
know
5 that these state=ents are true.
Our point of view is that there has not
7 been a direc: ca~:sal relationship established
by
clemt!!1c proc!, and, therefore, we don't know if
here is or is =at a causal relationship as this
:
10 document describes.
.1 :9-T 37-AR'-rNG CF?-6CT-R: When you say as
yo--Ive
12 testified previo%:sly, you're referring, are
yor.
13 not, to other state proceedings rather than
this
14 on&?
La T3--- Wz:xzSS: Yes. yorr Honor.
Is BY MR. SM:72:
17 Q. Now, in To*-Ir answer, you said "we" and
18 'it Is 0u r position."
19 Who are tl:e "we' and "our" != that
20 answer?
21 A. Well, :I= speaking for myself as well as
22 the SATCS board.
23 Q. Are there any scientists am the BATUS
24 board?
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2471
2 4 E
I No
2 Do a=y.scient!sts woric for BA:Us'?
3 A As you described 3A:=S, you're talk!=;
4 abcr--. a corporate o!:Icer !or BATUS?
5 BATUS or any of its subsidiaries.
6 Well, '-!' bolleve we do have 90=0
7 sc!&=TIs t9 at crr pape'r bus!ness and our
tobacccc
I business .
9 So Brown & Williamson employs soze
it or
10 scientis ts, correct?
11 A. 1 think go, Mr. Smith.
:2 Well, do you know what any scienzists
:hat.
13 who work for Brown & Williamson think as to
whether
in& to
:4 or mct there is a link between s=oiclng and
or
disease?
:6 A. I know what Brow= '41111a=som believes.
-act
:7 What does Brown & Williazson believe?
:3 They believe that there is has no% be*=
:9 a ca%:sal relationship between 9=oking and
disease
20 ttat has been scientifically proven.
Q What have they dome to explore that
iss-ae?
13 A. I do=lt have direct knowledge of that,
14 Mr. S=Ith.
a Is
rQ
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