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:

1. Confidential communications between Philip Morris USA, Inc. employees and Philip Morris USA, Inc. counsel, between Philip Morris USA, Inc. counsel or between Philip Morris USA, Inc. employees:

A. Confidential communications from Philip Morris USA, Inc. employees to Philip Morris USA, Inc. counsel.

B. Confidential communications from Philip Morris USA, Inc. counsel to Philip Morris USA, Inc. employees.

C. Confidential communications between Philip Morris USA, Inc. counsel.

D. Confidential communications between Philip Morris USA, Inc. employees containing, or for the purposes of obtaining, legal advice.

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, Inc. or another entity with a common interest.

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:

OWP (Opinion Work Product) containing counsel’s mental impressions, opinions, conclusions or legal theories.

FWP (Fact Work Product) containing facts obtained by counsel or at the request of counsel.

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, Inc.: