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Industry-Provided Depositions

[Re: Fax Cover Page]

Date: 23 Jun 1994
Length: 1 page
2025986550Exhibit117
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snapshot_pm 2025851310-2025854343

Abstract

Fax cover sheet for document 3155, from INBIFO to Philip Morris.

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Original document code was 3154.

Site
Minnesota litigation
Author
Gullotta, F P
INBIFO
Minor Subject
Tobacco Industry
Major Subject
Tobacco Industry
Recipient
Hayes, C S
Type
Fax

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Page 1: 2025851310
C_ampaign, Plan, cont~ d. Do ~NDUSTRIAL ALLIES AN~ FRIENDLY VOTERS The InitiaTive will have a major impact on. other industries in the State. Their financial resources and access to employees could substantially aid the cmmpaign. Additionally, there are large employee groups:-- particular}y those in, public service -- which may rebel against massive office space reallocations or blanket smoking prohibitions. The campaign will solicit contributio:ns from indus- trial allies and sympathetic employee groups. It will attempt to advance campaign arguments in company and employee association/union newsletters, trade publications, etc. A major Speakers Bureau effort will be undertaken to reach allied industrial and friendly voter groups at th,eir places o~ employment, trade shows, civic and social meeting.s, etc. Through the use of modern polling and '"cluster group analysis~'.. Zechniques, neighborhoods can be identified throughout the State which, have greater likelihood. of voting against the Initiative than the population at large:. These neighborhoods will be targeZed for heavy concentrations of computerized direct mail. Persons whose political affiliation,s or ethnic he#ditage indicates probable sympathy ~o, our cause .~ill be selected ~or targeted direct mail appeals. Ethnic groups will also be reached Through some ethnic rad:io and newspaper advertising. THE PUBLIC, THE MEDIA AND: THE LEGISLATURE OMerlaying all elements of the cmmpaign, there must be sensitivity to the long-term political~ impacts of campaign activities. Specifically, campaign actions must not damage industrial credibility with the med~ia, legislators, or State ~dministrators who will make the future ~inal decisions on ~aws or regulations to implement the Initiative, should our campaign fail to. defeat it. -5-
Page 2: 2025851311
Campaign. Plan,. cont'd While the 1980 Initia~iwe does. not contain many of the inconsistencies and weaknesses o~ it's 1978 predecessor, ~t is still an unnecessary, costly and unfair law. The pub%ic must be convinced that the issue is bro~der and more important than the question, of "clean air". The gen,eral population, the media an,d the Legislature must be made to see the Initiative as an, erosion of civil liberties, and as an unfair and divisive law. To accomplish this, there will be a broadening of the previous pool of contributors to the an,ti-regulation campaign. ~ajor efforts will be undertaken to obtain small contribu,tions from private ind:ividmals. Addition- ally, employee organizations and companies who are unrelated to the tobacco industry will be encou.raged to participate in the funding effort. A consistent !o~-key press relations operation will be commenced, stressing the key weaknesses of the law. Specific weaknesses are- The voters hav.e already voted~ against anti- smoking laws once before, at great expense to taxpayers ~or prin~ting of bal~ots and related election costs. This. measure establishes special rights for one class o~ citizens, a contradiction of the basic premise o~ our ~o~ernment system. The In,itiative will bring harm, and incon- venien,ce to. small companies, restaurants and many employees ~whether or not they smoke). The. measure is ~n, abuse of the Initiative process; for rather thmn allowing citizens the ability to, over-r±de ~he Legislature, it takes control away from the peoples' elected representaZfves andl gives complete contro,l to. appointed public employees, who are no~ accountable directly to taxpayer/ voters.. The only remedly people wi~l have ~o~ unfair or inept enforcement of the Initiative would: be another expensiwe initiative campaign, in future years, as the Californ~ia ConstituTion prohibits the Legislature from enacting laws which nullify statutes adopted by Initiative. -6-
Page 3: 2025851312
_Campaign Plan,, Cont'd As part of the effort to en,sure an on-going legis- lative environment conducive Io fair consideration, of industry positions, a program of legislative communication wil~ be developed. This communication will be preceded by "focus group" interviews conducted in appropriate settings by research professionals. ~t will help establish the main areas of agreement and disagreement between key legislators and California industry. These focus groups will also seek to identify the techniques and semantics which are most likely to strike respond- sire chords with, legislators and their staff. -7-
Page 4: 2025851313
V. CAMPAIGN BUDGET RESEARCH A. Focus Groups B. Polling C. Prior Vote Analysis $&O,O00.. 30,000. 10,000:. Research Subtotal ............... I Ij . CO~MHNICATION A. \;olunteer Programs I. Doorhangers (200m) 5,000,. 2. Point-of-Sale Brochures (imm): 20:,000.. 3. Matchbooks (lmm) 15.,000. 4~. Bumper Stickers (5m) 2,000. Volunteer Contact Sub¢o,tal ...... So DSrect Nail I. Fundraising Solicitations (300m) 65,000. 2. Consumer Contact (180m) 45,000. 3. V'oser Contact (2.4! ~o 3.2*mm)450,000. Direct Mail SubtoZal ............. IIl. ADMINISTRATION Ao E. F. G. H. I. Salary Legal and Accounting Management Travel Headquarters Rental Telephone Supplies Furniture & Eq:u,ipmen~ Payrol$ Taxes 92,000 20,000. 50,.000. 24,000. 12,000. lO,O00. 9,000. 6,000. 5,000. Administration Subtotal ......... TOTAL ............ $50,000. $42,000. 560,000. 228.,.000. 880,,000. Depending on Non,Profit Postage -8-
Page 5: 2025851314
Vl. CONTINGENCY The limited budget which has been. consid~ered for this campaign can defeat the Iniliative if public opinion begins to. change in our favor outside of th.e control of our campaign,. Activities of the proponents, a spontaneous assault by the news media, or public rebellion aEainsz another attemp~ to: further regulate a complex society., could all conZribute to such a favorable climate. The campaign will mon.i~or public opin,ion through a series of tracking s~ud~ies to be conducted during August and September. IZ public opinion begins to dramatically shift before the major direct mail expenditures of September and October, it may be prudent to s~gnifican~!y in,crease the campaign budge~ for ~ddi~iona! ad~ertising or direct mail communications. It is possible ~h,at these late expenditures cou,~d occur pri- marily during ~he period between September 25 and October 20; so ~hat the proponents w,ou,ld be unaware of an ~ncreased lev,el of campaign activity until the required spending reports are filed on October 23. This would be too late for ~h~e proponents to effectively reac~ ~o an increased level o~ campaign activity,. -9-
Page 6: 2025851315
~ V APPEN~D I CES Appendix 1 Appendix 2 Appendix 3 Organization CharZ Direcz Hail DeZail Cashflow i iii
Page 7: 2025851316
Appendix 1 CAMPAIGN ORGANIZATION CHART Press Coordinator] I Assistant I ] SecretaryI Northern California Coordinator l,, I~'Steering Committee 'I Robert Nelson & Associates Campaign Manager I Campaign Coordinator Administrative Assistant Secretary Coordinator Direct Mail production Speakers Bureau Coordinator Secretary ~ssenger
Page 8: 2025851317
Appendix 2: DIRECT'MA~L DETAIL Funidr~isingSolici~ations - TAN Members - Libertarians - Union.s, Associations ~embers - NFIB, Chamber of Commerce, etc. - Realtors - Restauranteu,rs - Graphics, etc. ~30m) (20m) ~ 130m ) (30r~) ( 2:0m ) (~0m) $: 6,000. 5,00:0. 35,000. 8,000. 4,000. 2',000. 5.,000. Fun,draising Subtotal .... $. 65,000:. ConsumerContact Mai~ Three letter to 60m Premium~con,test respon- dents Graphics, copy research, etc. 40,000. 5,000'. Consumer Contact Subtotal ........... $ 45,000. ¸. Voter Contact Mail - Access 500m:Mass Media names - Data Consu,lting - Match, file-to-~ile; selec~ Im target voter HR - Three letters to 800m - 1.~mm target voter HH - Graphics, research, copy $. 1,000. 4,000. 17,000. 4i18,000. I0,,000. Vo~er Contact Subtotal ......... $4i50,000:. DIRECT MAIL TOTAL .............. $56.0,000,.
Page 9: 2025851318
Appendix 3 RESEARCII A. Focus Groups B. Polling C. Prior Behavior II. COMMUNICATION h. Volunteer Programs 1. Doorhangers 2. Point of Sale Brochures 3.: Matchbooks 4. Bumper Stickers CASH FLOW TOTAL 6/t-7/25 $10,000 30,000 $10,000 10,000 5,000 5,000 20,000 15,000 2,000 B. Direct Mail t. Fundraising Solicitations 65,000 2. Consumer Contact 45,000 3. Voter Contact 450,000 IV. ADMINISTRATION A, Salary 92, B. Legal and Accounting 20 C. Management 50 D, Travel 24 E, lteadquarters Rental 12 F. Telephone 10 G. Supplies 9 H. Furniture & Equipment 6 I. Payroll Taxes 5, PERIOD TOTAL CUMULATIVE REPORTING TOTAL 15,000 t5,000 10,000 000 000 000 000 000 000 000 000 000 17,000 4,000 10,000 6,000 6,000 4,000 3,000 2,000 1,ooo 108,000 108,000 (Reporting Periods) 7/25-9/23 9/24-10/20 $ 8,000 20,000 5,OOO $ 2,000 5,000 5,000 5,000 10,000 10,000 2,000 25,000 50,000 25,000 15,000 ].50,000 37,000 8 000 20 000 9 000 4 000 5 000 4 000 3 000 2 000 210,000 318,000 25 000 4 000 10 000 6 000 2 000 1 000 1 000 1 000 1 000 270,000 588,000 !0/21-1t/30 $ 5,000 15,000 240,000 13,000 4,000 10,000 3,000 1,000 1,ooo 292,000 880,000
Page 10: 2025851319
° C~mpai~n Plan, cont'd. Do INDUSTRIAL ALLIES AND FRIENDLY VOTERS The Initiative will hav.e a major impac~ on other indu,stries in the S~ate. Their financial resources and access to. employees could substantiall'y aid ~he campaign. Additionally, there are large employee groups -- particularly those in public' serv.ice -- which may rebel against massive office space reailocations or blanket smoking prohibitions.. The campaign will solicit con~ribution:s from, ~nd,us- trial allies and sympathetic employee groups. I~ will a~temp,t to advance campaign arguments in, company and employee association/union newsletters, trade publications, etc. A major Speakers Bureau effort will be undertaken ~o reach allied industrial and friendly voter groups at th,eir places of employment, trade shows, civic and social meetings, etc. Through the use of modern polling and '"cluster group analysis" techniques, neighborhood~s can. be identified throughout the State which have greater likelihood of voting a~ainst the Initiative than the population ~ large. These neighborhoods will be targeted ~or heavy concentrations: of computerized direct mail. Persons whose political affiliations or ethnic heritag.e indicates probab%e sympathy to our cause will be selected! for targeted direct mail: appeals. Ethnic groups will also be reached ~hrou~h some ethnic raddo and newspaper advertising. TKE PUB~IC~ THE MEDIA AND THE LEGISLATURE Overlaying all elements o~ ~he campaign., there must be sensitivity to the long,term political impacts o~ campaign activities. Specifically, cmmpaiEn actions must not damage industrial credibility with the media, legislators or State administrators who will make ~he future ~inal decisions on laws or re~u.lations to implement the In,itiative, shou~Id our campmign: fail ~o defea~ it. -5-

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