Tobacco Documents Online

KA50WITZ, BENSON, TOEEES 8c FEIEDMAN LLP cc: Stanley S. Arkin, Esq. Marc N. Bell, Esq.

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 1301 AVENUE OF THE AMERICAS NEW YORK, NEW YORK 10019-6022 wn~R s eiwccr o1.u NuM®sA 212-.506-1700 700 LculSUWS srRErr NOW'TON, TCU$ 77C02 (212) SO6-1721 FACSIMILE: 212-506-1800 7,3-22c-aacO August 7, 1998 Bv Facsimile and RecTular Mail Walter P. Loughlin, Esq. Latham & Watkins 885 Third Avenue Suite 1000 New York, New York 10022 Re: Brooke Group Ltd. and Liggett GrouiD Inc. Dear Mr. Loughlin: I am in receipt of copies of correspondence between you and Stanley Arkin concerning Liggett-related documents that I understand to be in your firm's possession or control. As you know, our firm is national counsel to Liggett in tobacco product liability litigation. Liggett-related documents in Latham & Watkins' possession or control possibly are responsive to document requests in several tobacco-related cases. Accordingly, on behalf of Liggett, I request that your firm immediately make all such documents available for review,and copying by Liggett's current counsel. Your assertions in correspondence that privilege claims of other tobacco companies prevent Latham & Watkins from providing Liggett or Liggett's current counsel access to documents which relate to representation of Liggett are baseless and legally untenable. Please advise me by 2 p.m. on Tuesday, August 11, 1998 as to whether Latham & Watkins is going to permit Liggett's current counsel access to its client's files. Please further advise me of a time during the week of August 17 when the review of such files may begin. Liggett will compensate Latham & Watkins for reasonable costs incurred in assembling the Liggett-related files for our review. Very truly yours, Aaron H. Marks