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c EXH . L~ z-- ~oR ioE,vN i=1-Etic,g,+ OaTE •!-LI ~at;~~~iJC= ~REC~i3_- 3UP'RENfL .:oU8T OF THE 5TAi.E`JF fl>:W YORK COUNTY OF FI~EW YQliK ..Exhibitr ~`'fdeat.\~G........EYid. ...1.!... Date ... » ...~'...: /..~...~ ................................. ~ Dolores J. Ryan, C.S.R. Official Court Reporter May 25, 1972 F ';'=si Pil.cnele ° r Cro,.'.= Attornev Federal Trade Cor..-ti.ssion Bureau of Consuner Protection Washington, D.C. 20580 re: 'File P4o. 722 3232 ~ Lorillard Co., et.all ~ : Dear Madam: , In response to your letter of May 9, 1972, we enclose document,3tion replying to the auestions you asked. In the spirit of cooperation, I hope the anstiiers will be h&&pful to your office. Sincerely yours, encls. 4 Robert 2A. Sarael.:.an President

re: letter 5/9/72 1. Robert Brian Associates, inc- I07 East 38t.% Street Nev- . Yor}., N.Y. 10016 for clients of the agency. 200 shares .Y. no stock. no stock 733 Third Avenue, New York, 11.1% Cornorate Activ;ties: We were incaraorated to engage fn the design, execution and production of sales pror..otion prograa:s and caapaigns S tanley B. Sigmzn, Secretary 78 E'aizway Avenue, Verona, N.J. Burton 2. Monasch, Treasurer Incoraarated : Ne:: Yor.: S tat` , la :Z_ Cornorate 0=ficers : Ro ;ert M. Sandelinan, Presiden t 114 Ascan Avenue, Forest Hills, 11 :Sumber of employees : S 0 Gross revenues for 1971: ;59g,203.30 2. No written contract ever existed. We were employed by the Lorillard Co., 200 East 42nd St., New York, as sales promotion agency on a montzlv retainer for a period of 15 months, commencinc June, 1970. The monthly retainer, wnich a.:.our.ted to $6,000 ner rsont_z, was paid. to us for the creation and development of ideas, layouts and copy theme s . 3. The following empLoyees worked on the Kent Castle Contest: Robert !S. Sanc3e -^an, president. Directed the creative activities of copy and art departments an:: presided at copy sessions. Jerrr aosenfeld, art director. Particiaate dLn creative sessions and-conceatually visualized e.^tire promotion.

• Federal Tr'adACor.imi.ssion Phil Gaberman, copy writer - no longer in our employ Wrote whatever_copy was required for the promotion, collateral materials, and directed outside copy sources. Bob Orth - assistant art director - no longer in our er.plo_:. Assisted art director in visualizing and rendering finished mechanicals for all the n_ronotional materials. Stanley Sigman, productinn manager Supervised in-=Eant prodLctioa of all promotional:. zzaterials. Maurice Johnson, account executive - no longer in our employ. Functioned as account executive and liaison between agency aad client, initiating some of the corzes- ~- • pondence between both companies Shirley Hirschhorn, bookkeeper Kept records and books and rendered invoices to the client for in-house charges and outside costs. Nancy Mahoney, typist - no longer in our e-maloy Typed all pertinent corEespondence and reports. Promotional expenditures dismersed b_v Lorillard on this campaign with our agency: $196,149.66 T,,7e . have, and had then, no connection wi.th'Blue Ribbon other than hi i.zg and negotiating with them on behalf of Lorillard, to judge the said contest. At the client's request, we interviewed 26"ir. Don Jagoda, president of Blue Ribbon, 'and on the basis that his company had judged con- tests of this nature be=ore for major accounts, we were convinced he would bring his ekpertise to the judging and winner selection and peform expertl_v and responsibly.. Blue Ribbon established the rules for judging the contes t and selecting winners. Attached is a copy of our contract a with thera. We had never been involved with Blue Ribbon in a business capacity prio= to the Kent Castle contest pro- motion.