STATE 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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