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Council for Tobacco Research

Cipollone V. Ligget, Et Al. Our File No. 03356-113151 [Request to Present at Interview by Counsel]

Date: 12 Sep 1986
Length: 2 pages
CTRMN014665-CTRMN014666
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snapshot_ctr CTRMN014665_4666

Fields

Type
LETTER
Depository Date
25 Sep 1995
Master ID
Ctrmn00014501-5129
Related Documents:
Recipient
Hartzell, A., Debevoise And Plimpton
Author
Edell, M.Z., Budd Larner Gross Picillo Rosenbaum Gree
Box
007
Request
118
UCSF Legacy ID
uds30a00

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Page 1: uds30a00 Log in for more options!
5 UDD LAR,,4 ~~ Gr~C~S ?I C;L.'_0 RoSc^+Bat,M GR ccNa c; G 3., A PROFESSIONAL CORPORATION COUNSELLORS AT LAW .... o . ~rr:.) ... -.....••ostre...,. ...... . .,.t• _ ..asra.c •.o....h ~. s.o. •ch..O a wslo. .. . f•.......h c•.O . ro..c. ..C l .0.- S.tr.. • C.... c .... . ..... .Owrh. ..•-.ws :....so .C.t.. r0•aC. .trh..- ! ..•.. !•l+tr a -th.. •w-,.. .t•.. . .•w. o •.o.....o ,SO JO••N F -(ENNEOV DAAKWAV CN 1000 S'.ORT •+IllS N J 0707}0999 201.379-,4500 ,u.a_ . ,_.....o~ .o-r a :..•t• . ..- •t .... c._..! .,..rro -...•.._e • ..coa ..._.u•. c ..c...... ...s... ...c.. ...-~tth.. ..... - C.h...... •O.•hO OOw•.. c....l.o._.. , C.... .os." . ••C•..o s•..t•. .. .,c•....h .c.~ ..h ,s... •0.../ . lO.wth1•.~h ..Cw..0 O •-C..w .O...h O .-.. .0..•.. COSLO- -1...u ..- ..o..h• ..ot.. : ........... . .•t.! ...o• . ~...c_...o u C..... :. vf..•!.. u u !•t•-tr.. -u~Otr _to.~..o . .. O. COUhf!• s.,...t. . ...h.. .O•••. ,Ost••. .u00 Oo.00.. • ..•.• C •..OU.. aC•..•.•ho ~~.0..•..)r .. - ... 0.11 September 12, 1986 Andrew Hartzell, Esq. Debevoise & Plimpton. 875 Third Avenue New York, NY 10022 nE5'v~•.' •. . i J9 5C 9 i: a a.EaSE at>.• '_ Short Hills RE: Cipollone v. Liggett, et al. Our File No. 03356-113151 Dear Mr. Hartzell: This will confirm our telephone conversation of September 10, 1986. You will recall that on September 9, 1986 I attempted to contact Dr. Sommers in response to Patrick Sirridge's letter to me of September 3, 1986 which was received in my office on September 8, 1986 concerning a meeting which was to occur on September 9, 1986. I will not reiterate my feelings concerning your handling of my telephone call to Dr. Sommers and then to you of that date. I will only state that my purpose in attempting to contact Dr. Sommers was to ascertain whether or not he would permit me to be present when he was interviewed by the counsel for the defendants regarding his care and treatment of Rose Cipollone. On the morning of September 10, 1986, I received a telephone call from William Shinn who advised me of his intent to continue the meeting with Dr. Sommers and was going to advise me as to further dates on which he also intended to meet with Dr. Sommers. Subsequent to that telephone conversation, I received a call from you in which I conveyed to you my request to be present during any interviews of Dr. Sommers by the defendants insofar as his care and treatment of Rose Cipollone was concerned. You advised me that neither you nor Dr. Sommers thought that it was appropriate for me to attend any such meeting. Ct F'+a t Ft't 0 14665,
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g..)D ,Aa.,ca :i?OSS DiGIC_O aOSE'vsauU GPEEV8ERG ! 5•aJE ~ »Cce Si Cv.t CCnspA.t Cti Andrew Hartzell, Esq. September 12, 1986 Page Two It was not my intention to obtain permission from Dr. Sommers to attend any meetings with defense counsel pertinent to his responsibilities at CTR or any facts which he may ha•>> knowledge of pertinent to CTR. In addition, it was not my intention to attend any meetings of defense counsel with Dr. Sommers pertinent to his participation in this case as an expert on behalf of the defendants. Having been advised by you that Dr. Sommers would not agree to have me present during his meeting with defense counsel, I inquired as to whether or not he would be willing to meet with me to discuss his care and treatment of Rose Cipollone at some other time. You advised me that since I had scheduled Dr. Sommers' deposition for the beginning of October, you felt that there was no need for me to meet with him on an informal basis. I did, however, reiterate my request to meet with him prior to that deposition but you indicated that that would not be acceptable. In the event that this letter does not accurately reflect either your or Dr. Sommers' position in regard to my requests, I would appreciate it if you would so advise me. I have not taken the liberty of sending a copy of this to Dr. Sommers since you advised me that you represent Dr. Sommers not only in his capacity as an employee of CTR but also individually insofar as anything that may relate to this case. I would appreciate it, therefore, if you would furnish Dr. Sommers with a copy of this letter so that there is no misunderstanding as to what his position is regarding my requests. C! RHI! `t 014(;G(;

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