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
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,
AFFIDAVIT OF JONATHAN M. REDGRAVE IN SUPPORT OF DEFENDANTSí MOTION TO COMPEL INITIAL DEPOSITIONS OF MEDICAID RECIPIENTS
STATE OF MINNESOTA )
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 Corporation in the above-captioned litigation.
2. Attached as Exhibit A is a copy of excerpts of the transcript for the March 10, 1995 hearing in the above-captioned matter before the Honorable Kenneth J. Fitzpatrick.
3. Attached as Exhibit B is a copy of Peter Bierstekerís September 7, 1995, letter, on behalf of defendants, to Roberta Walburn, counsel for plaintiffs.
4. Attached as Exhibit C is a copy of Thomas Hamlinís September 29, 1995, letter, on behalf of plaintiffs, to Peter Biersteker.
5. Attached as Exhibit D is a copy of Peter Bierstekerís October 6, 1995, letter to Thomas Hamlin.
6. Attached as Exhibit E is a copy of Thomas Hamlinís October 17, 1995, letter to Peter Biersteker.
FURTHER YOUR AFFIANT SAYETH NOT.
Jonathan M. Redgrave
Subscribed and sworn to before me
this 8th day of November, 1995.
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