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Information About Using this Website
Website design
This website is designed to provide the public with access to documents produced by
Philip Morris USA in Attorney General reimbursement lawsuits and certain other
specified civil actions, and to documents produced after October 23, 1998 through
June 30, 2010 in smoking and health actions, and includes certain enhancements, all as
provided for by paragraph IV of the Attorneys General Master Settlement Agreement (MSA).
The enhancements include an expanded index to documents, with up to thirty-two searchable
fields of information. The viewing and navigational tools have also been enhanced to include
full image viewing and enhancement functions as well as a larger viewable area. In addition,
a return to search results button has been added to allow efficient previewing and searching
of documents. The Philip Morris USA Privilege Log is now available on this
site. Important information
about documents on this website is also provided for reference purposes.
This website is intended for informational, educational and non-commercial use only. In
order to provide efficient access to a large volume of documents, this website uses three
main tools: (1) Document indexing; (2) Index searching; and, (3) Automatic linking of search
results to images of the retrieved document index entries.

Document Indexing
The documents are indexed by the following information: Document Identification number
(Did), Master ID (Mid), Other Number (Onumber), Document Date (Ddate), Primary Type (Ptype),
Other Type (Otype), Person Author (Pauthor), Person Recipient (Precipient), Person Copied
(Pcopied), Person Mentioned (Pmentioned), Person Attending (Pattending), Person Noted (Pnoted),
Org Author (OAuthor), Org Recipient (Orecipient), Org Copied (Ocopied), Org Mentioned
(Omentioned), Org Attending (Oattending), Org Noted (Onoted), Physical Attachment1
(Pattachment1), Physical Attachment2 (Pattachment2), Characteristics (Characteristics),
File Name (Fname), Site (Site), Area (Area), Title (Title), Old Brand (Obrand), Primary
Brand (Pbrand), Mentioned Brand (Mbrand), Page Count (Pcount), Request Number (Rnumber),
Date Loaded (Dloaded), Litigation Usage (Usage).
The documents are also indexed by "compound fields" where the user can implement a search
that will encompass a range of fields: Id - Document ID, Master ID; Type - Primary Type,
Other Type; Person - Person Author, Person Recipient, Person Copied, Person Mentioned,
Person Attending and Person Noted; Organizations - Org Author, Org Recipient, Org Copied, Org Mentioned,
Org Attending, and Org Noted; Brand - Primary Brand, Old Brand, Mentioned Brand;
Author - Person Author and Organization Author; Recipient - Person Recipient and
Organization Recipient; Copied - Person Copied and Organization Copied; Mention - Person Mention
and Organization Mention; Noted - Person Noted and Organization Noted; Attend - Person Attend
and Organization Attend. Detailed information about the Index to
these documents is provided. In addition this website contains full text of
plaintiffs Request for Production of documents in
State of Minnesota, et al. v. Philip Morris Incorporated et al.

Searching the Index
The document index can be searched using the familiar Alta Vista™
search engine. This search engine returns results based upon a ranking
of the presence of search terms in the document index.
You can perform simple or advanced (Boolean) searches by using the Alta Vista™ search procedure. For performing a simple search, this procedure supports the basic operators + and - which indicate words or phrases that are required or prohibited in the search results. Alta Vista™ also allows advanced search capabilities that support the Boolean logic operators AND, OR, NOT, and NEAR, as well as the ability to specify ranking words
that are different from the words in the search query.

Understanding Simple and Advanced Search
Both the simple and advanced search procedures follow the same basic
rules for processing queries. The search engine interprets a word as any
combination of letters and numbers. Alta Vista™ searches ignore punctuation except to interpret
it as a separator for words.
Key points include:
- A group of two or more words enclosed in double quotes (e.g., "tobacco company")
indicates a phrase. Phrasing ensures that the search engine finds the
words together, instead of looking for separate instances of each word
individually.
- Two asterisks (**) following three or more characters (i.e., wildcard), will find all words that begin with the characters selected.
- Search Terms are case sensitive. All search terms
should be typed in lower case (e.g., tobacco), or upper
case (e.g., TOBACCO). Searches using mixed case (e.g.,
Tobacco), will not result in any "hits" on this site.
Using logical operators listed below to refine a search
Both simple and advanced search support the use of various operators that can help you refine the results of a search.

Simple Search Operators
Simple search supports two basic operators:
| Operator |
Function |
| + |
includes only index entries containing all
specified words or phrases in the search results |
| - |
excludes index entries containing the specified word or phrase from the search results |
To perform a basic search, use the operators plus (+) and minus (-) to indicate words or phrases
that are required or prohibited in the search results. For example, the following query
expression requests documents that must contain the word results and can also contain the
phrase year end:
"year end" +results

Advanced Search Operators
The following are the advanced search operators and their meaning:
| Keyword |
Symbol |
Action |
| AND |
& |
Finds only index entries containing all of the specified words or phrases. |
| OR |
| |
Finds index entries containing at least one of the specified words or phrases. |
| AND NOT |
& ! |
Excludes only index entries containing all of the specified words or phrases. |
| OR NOT |
| ! |
Excludes index entries containing at least one of the specified words or phrases. |
| NEAR |
~ |
Finds index entries containing both specified words or phrases within 10 words of each other. |
For example
The following query requests that either of the words apple or pear appear in the same index entry with either of the words tart or pie.
(apple OR pear) AND (tart OR pie)

Specifying A Field In Your Search
You can limit your search to specific field(s) by using the syntax:
field: search string
For example, the following query searches for the word training in the document's Title field.
title: training
Each field in the index can be specified in your search using the following search items:
| Field Name |
Search Term |
| Document Id | Did: |
| Master Id | Mid: |
| Other Number |
Onumber: |
| Document Date |
Ddate: |
| Primary Type |
Ptype: |
| Other Type |
Otype: |
| Person Author |
Pauthor: |
| Person Recipient |
Precipient: |
| Person Copied |
Pcopied: |
| Person Mentioned |
Pmentioned: |
| Person Attending |
Pattending: |
| Person Noted |
Pnoted: |
| Organization Author |
Oauthor: |
| Organization Recipient |
Orecipient: |
| Organization Copied |
Ocopied: |
| Organization Mentioned |
Omentioned: |
| Organization Attending |
Oattending: |
| Organization Noted |
Onoted: |
| Physical Attachment1 |
Pattachment1: |
| Physical Attachment2 |
Pattachment2: |
| Characteristics |
Characteristics: |
| File Name |
Fname: |
| Site |
Site: |
| Area |
Area: |
| Title |
Title: |
| Old Brand |
Obrand: |
| Primary Brand |
Pbrand: |
| Mentioned Brand |
Mbrand: |
| Request Number |
Rnumber: |
| Date Loaded |
Dloaded: |
| Date Record Updated |
DUpdated: |
| Litigation Usage |
Usage: |
Alta Vista™ operators can be used in conjunction with specifying a term in your search. For example, the following
query requests that both the words software and training appear in the document's Title field.
title: (software + training)

Searching Using Dates and Date Ranges
There are three types of dates that can be used when searching for documents; Document Date, Posted Date and Date Record Updated. The search terms that correspond to these fields are ddatev:, ldatev: and udatev: respectively. The Document Date is the date of the document, and the Posted Date is the date which the document was loaded to the website. The Date Record Updated reflects the date the document was modified with replacement images (if the document has not been updated, then this value will be null).
In the Document Date field, there may be suffixes applied to the date value to provide additional information.
The suffix codes that may be appended to the Document Date are:
| Code | Description |
| E | Estimated Date |
| F | Date Filed |
| P | Date Published |
| R | Date Received |
| D | Date Spans |
| Q | Quarterly |
| S | Semi-Annually |
| Y | Yearly |
The following suffix codes will appear for electronic documents where natively available metadata is used to populate the date field:
| Code | Description |
| DM | Date Modified |
| DC | Date Created |
| DS | Date Sent (only applies to emails) |
For example, if a Microsoft Word document was last modified on July 17, 2007, the Document Date value would be indexed as "20070717/DM". The search results would appear as as "20070717 (Date Modified)".
There are two search terms available to use for each date value. For example, ddate: and [ddatev:], can be used when searching Document
Date. Use ddate: when searching for a specific date. For example, if you know a document is
dated April 18, 1977, enter the following search:
ddate:19770418
Another good use of ddate: is a search for all dates in a specific month or
year. For example, to find all documents dated in1983, use the following search:
ddate:1983**
To find all documents dated in February, 1992, enter:
ddate:199202**
The search term [ddatev:] is used for range searching. For example, to find
all documents dated within the week of May 3-10, 1988, enter:
[ddatev:19880503-19880510]
A range search can span any number of days, weeks or months. To find
all documents dated between July, 1981, and September 30, 1984, enter:
[ddatev:19810700-19840930]
The same guidelines as described for Document Date can be used for the
Date Loaded or Date Record Updated fields. The search terms are:
dloaded: or [ldatev:] for Date Loaded
dupdated: or [udatev1:] for Date Record Updated

Understanding Relevance Ranking
Document index entries retrieved as a result of a search are ranked based upon the number of words in a search query that they contain. The index entries containing the most search words will be ranked the highest.

Viewing Your Selected Document
Once you have selected a document it can be viewed in one of two ways:
- Page by Page - This option gives you the ability to view/print single pages of the document, one at
a time. While viewing the page you will have the ability to rotate it 90 degrees to the left or
to the right to adjust for landscape images. This is the default page view.
- View All - This allows you to view and or print an entire document continuously. This is the recommended choice
for printing the entire document. This feature may be accessed by pressing the "view all pages" button in the page view window. To return to the page view window, press the "back" key on your browser.

Litigation Usage Field - Term Definition
| Privilege Withdrawn |
Documents for which Philip Morris USA withdrew, in whole or in part, claims of privileges or protections in the re-examination of claims of privileges or protections undertaken pursuant to Court Order in State of Oklahoma v. R.J. Reynolds Tobacco Co., et al., CJ-96-2499-L (Dist. Ct., Cleveland Co.) |
| Trial Exhibit |
Documents produced by Philip Morris USA that were also listed by
plaintiffs' counsel as a trial exhibit. |

Philip Morris USA Privilege Log
The Consolidated Privilege Log contains entries for over
100,000 documents withheld from production, in Attorney General actions and
other specified civil smoking and health actions, based upon claim(s) of
attorney-client privilege, work product protection and/or joint defense/common
legal interest privilege. The Privilege Log is available for
viewing and searching.
To search for a specific record, please enter the Bates number (Document ID) in the search window. Due
to ongoing productions, entries will be added and/or revised from time to time.
Field descriptions, the Index to Privilege and Protection Codes
and other explanations are provided here in the Privilege Log’s help
section. The Glossary
of Names for the Privilege Log is also
available.
The following chart contains information regarding the fields contained in the Privilege Log.
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DOCUMENT ID:
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A ten-digit number is used to identify each page of a document.
The Id is expressed as a range when it refers to a multi-page document;
a forward slash (/) is used to separate the first page from the
last page. On occasion, the Id will contain an alpha suffix in the
ninth position. It is possible to retrieve a specific privilege
log entry when the Id number for the first page is known by entering
that number in the Adobe Acrobat ® search box. Documents that have been produced with privileged information redacted are identified "Redacted Document."
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DOCUMENT DATE:
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Dates are recorded as either YYYYMMDD or YYMMDD. An estimated date is identified with an "/E".
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AUTHOR:
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This field contains the name(s) of individual(s) who created the document. Each name is recorded
with the last name first followed by first and middle initials when
available.
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RECIPIENT:
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This field contains the name(s) of individual(s) who received the document. Each name is recorded with the last name first followed by first and middle initials
when available.
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COPIED:
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This field contains the name(s) of individual(s) who were copied on the document. Each name
is recorded with the last name first followed by first and middle
initials when available.
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TYPE:
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This field contains a description of the document's physical format.
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DESCRIPTION:
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A
description of the nature of the document withheld as privileged and/or
protected. |
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DESIGNATION: |
See the Index to Privilege and Protection Codes below. |

Index To Privilege And Protection Designation Codes
Attorney-Client Privilege
Documents found in the following categories contain legal advice, requests for legal advice or services, or provide information in connection with the rendering of legal advice or services:
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1. | Confidential communications between Philip Morris USA employees and Philip Morris USA counsel, between Philip Morris USA counsel or between Philip Morris USA employees:
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| | A. | Confidential communications from Philip Morris USA employees to Philip Morris USA counsel. |
| | B. | Confidential communications from Philip Morris USA counsel to Philip Morris USA employees. |
| | C. | Confidential communications between Philip Morris USA counsel. |
| | D. | Confidential communications between Philip Morris USA employees containing, or for the purposes of obtaining, legal advice. |
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2. | Confidential communications between employees or counsel and the employees or counsel of an agent, confidential litigation consultant, or informal consultative expert of Philip Morris USA or another entity with a common interest.
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Work Product
Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by the client, a representative of the client, the attorney, or a representative of the attorney:
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OWP (Opinion Work Product) containing counsel’s mental impressions, opinions, conclusions or legal theories. |
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FWP (Fact Work Product) containing facts obtained by counsel or at the request of counsel. |
Joint Defense
Documents found in the following categories contain legal advice, requests for legal advice or services, or provide information in connection with the rendering of legal advice or services and/or reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by the client, a representative of the client, the attorney, or a representative of the attorney and other companies, their employees, their counsel and/or agents with a common interest or in a joint defense with Philip Morris USA:
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3. |
Confidential communications between Philip Morris USA employees or Philip Morris USA counsel and the employees or counsel of another entity with a common interest:
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A. |
Confidential communications between Philip Morris USA counsel and the employees or counsel of another entity with a common interest. |
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B. |
Confidential communications between Philip Morris USA employees and the employees or counsel of another entity with a common interest. |

Philip Morris USA Case Names
Case name codes are used in the Request Number and Litigation Usage fields in place of longer, case citations. The codes in use on this website and the case they represent are:
| ABCD |
Philip Morris Companies Incorporated, et al. v. American
Broadcasting Companies, Inc., et al.
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ACTR
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Screen Actors Guild, et al. v. Philip Morris
Incorporated, et al.
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| ASPN |
Lori Aspinall v. Philip Morris
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AZAG
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State of Arizona v. American Tobacco Company, Inc., et
al.
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BCNJ
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Blue Cross Blue Shield of New Jersey v. Philip Morris
Incorporated et al.
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BECK
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Michael Beckman v. Brown & Williamson Tobacco Corp., et al.
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| BIFL |
Vincent Bifolck v. Philip Morris, Inc., et al.
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| COSL |
City of St. Louis, et al. v. American Tobacco Company Inc., et al.
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| CRFT |
Craft v. Philip Morris Cos., Inc. et al., 002-00406-02 (Mo. Cir. Ct.)
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BLNK
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Blankenship v. Philip Morris Incorporated, et al.
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BROI
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Broin v. R.J. Reynolds
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BULL
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Jodie Bullock vs. Philip Morris USA, Inc
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| CHRS |
Nona Christensen v. Philip Morris Incorporated, et al.
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| CURT |
Gregory Curtis, et al. vs. Altria Group, Inc. and Philip Morris USA Inc.
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DANI
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Devin Daniels, et al. v. Philip Morris Incorporated, et al.
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| DEJO |
Ada Violeta Araujo Dejo v. Philip Morris Companies, et al.
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ENGL
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Engle, et al., v. R.J. Reynolds et al.
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| FAHE |
Luanne Fahey v.Philip Morris Incorporated, et al.
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FALI
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Robert Falise (Trustees of Manville Trust) v. American
Tobacco Company, et al.
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FEDA
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United States of America; Dept. of Justice v. Philip
Morris Incorporated, et al.
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FIBR
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Fibreboard v. American Tobacco Company et al.
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FLAG
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State of Florida v. American Tobacco Company, et al.
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| FRSI |
Rose Frosina, et al. v. Philip Morris Inc., et al.
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| GRIS |
Leslie Grisham v. Philip Morris Incorporated, et al.
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HALL
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William Hall, et al. v. Philip Morris Incorporated et al.
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| HARS |
Richard P. Harshbarger v. Philip Morris Incorporated, et al.
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IEYO
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Ieyoub v. American Tobacco Company, et al.
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INSO
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Vincent Insolia, et al. v. Philip Morris Incorporated,
et al.
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IWGN
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Iowa General Cases v. Philip Morris Incorporated, et al.
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IWOH
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Iron Workers Local Union No. 17 (Ohio) Insurance Fund,
et al. v. Philip Morris Incorporated, et al.
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| JENS |
Sharilyn Jensen v. Philip Morris Incorporated, et al.
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| KADY |
Karl Karandy v. R. J. Reynolds Tobacco Company, et al.
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KING
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King v. Philip Morris Incorporated, et al.
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KYLT
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Kentucky Laborers District Council Health & Welfare
Trust Fund, et al. v. Philip Morris Incorporated, et al.
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LEON
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Anita Leon, et al. v. Philip Morris Incorporated, et al. PM Broin Progeny
al.
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| LONG |
Julien Longden v. Philip Morris Inc., et al.
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MAAG
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Commonwealth of Massachusetts v. Philip Morris Inc., et
al.
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MDAG
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State of Maryland v. Philip Morris Incorporated, et al.
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| MEHL |
Myron Mehlman v. Philip Morris, Inc., et al.
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MICH
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Marisa Mitchell, et al. v. Philip Morris Incorporated, et al.
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MILE
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Sharon Price et al. v. Philip Morris Companies Inc. et al. (f/k/a Susan Miles v. ...)
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MOAG
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State of Missouri v. Philip Morris Incorporated, et al.
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MORM
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In re Mike Moore, Attorney General, ex rel., State of Mississippi
Tobacco Litigation
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| NOCA |
No Case
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NYAG
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State of New York, et al. v. Philip Morris Incorporated,
et al.
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OKAG
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State of Oklahoma v. R.J. Reynolds Tobacco Company, et
al.
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ORAG
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State of Oregon v. American Tobacco Company, et al.
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PECH
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Pechanga Band v. Philip Morris Incorporated, et al.
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| PISC |
John Piscetta v. Philip Morris USA Inc.
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| POCA |
People of the State of California v. Philip Morris, Inc., et al.
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PPLA
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People of the State of California, et al. v. Philip
Morris Incorporated, et al. (Superior Court, Los Angeles County)
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PPSJ
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People of the State of California, City of San Jose, et
al. v. Brown & Williamson Tobacco Corporation, et al.
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REIL
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Philip Morris Incorporated, et al. v. Thomas F. Reilly,
Attorney General of the Commonwealth of Massachusetts
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| RIOB |
State of Rio de Janeiro v. Philip Morris Incorporated, et al.
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RODG
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Rodriguez v. Philip Morris Incorporated, et al.
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SCOT
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Scott v. Philip Morris Incorporated, et al.
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| SHIP |
Shanna Shipman v. Philip Morris, Inc., et al.
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STMN
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State of Minnesota, et al. v. Philip Morris
Incorporated, et al.
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| SWAB |
Barbara Schwab, et al. v. Philip Morris USA Inc., et al.
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THOM
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Ezell Thomas, et al. v. R.J. Reynolds Tobacco Company et
al.
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TXAG
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State of Texas, et al., v. American Tobacco Company, et al.
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VTAG
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State of Vermont v. Philip Morris Incorporated, et al.
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WAAG
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State of Washington v. American Tobacco Company, et al.
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| WALD |
Walden v. R.J. Reynolds Tobacco Company, et al.
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| WTVA |
West Virginia Consolidated Cases
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