Tobacco Documents Online

6 7 8 9 I0 !I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 case, including internal company documents of any defendant in this case." Are there any documents that fall under paragraph 7 that have been produced or should be produced to me? A No. " Q Have you reviewed any internal company documents in this case or in any other case? A No. Q Have you read any deposition testimony of any other expert witnesses in this case? A Expert witnesses for the plaintiff, yes. Q And who would that be? A Martin Goldbergand Dean Krugman. Q You said that you had a conversation with David Goff several weeks ago. What was the purpose of that communication? A I wanted to know if he had ~vailable copies of articles from the J~ck~on Clarion Ledger. were you asked to review the depositions of Dr. Goldberg and Dr. Krugman by the defendants in this case? A Pardon me? Q" were you asked to review the depositions of Dr. Goldberg and Dr. Krugman by the defendants.in this case in preparation for your testimony? .11

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q so of what they plaintiffs? A Yes. Vita. Yes. you-just basically made yourself intended to testify on behalf of aware the And I've had premarked as Exhibit 2 your I'll ask you to take a look at that. It's kind of a crooked copy, ~orry, and just make sure it's complete and current. A (Reviewing document.) The only thing not listed is, and it's a minor item, on page 2-- excuse me, page 3, it doesn't show my-- the courses I taught autumn quarter 1996, which would have been last quarter, or the courses I'm finishing up now~ is our winter quarter. So it's.page 3 of the as the which Vita, but that's-- they're exactly the same ones listed for autumn of '95. Q Okay. Did you go directly from high school to undergraduate? A Yes. Q And I see from your work experience on page 2 you've been with since you received your Ph.D.; That is correct. of Utah correct? A history the University is that 12

1 2 3 4 5 6 7 8 9 I0 ii 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 Q Are you a tenured profess.or? A Yes. When did you receive your tenure? A 1981. So you've never had any other work experience other than in the academic field being an expert witness? A Yes. Or consulting preparations. Q What type of consulting do you do? A Most of my consulting has to do with and strategy, communications programs for industries. a list, I know it won't be companies you've consulted advertising different clients, different Q Can you give me a11 inclusive, of several with over the years? A Yes. One would be about American . Investment Bank, which is a subsidiary of Leucadia National Corporation in New York; ~IBM, which has a local sales and marketing office here in Salt Lake City; AT&T, which also had a Salt Lake City Office, the Jerry Seiner Group which is a large mega dealer, automobile dealership here; several small firms, Zion Laser Technology, which has patented laser technology for teet-h whitening processes. The ~ resort group which manages condominiums for• absentee 13

1 2 3 4 5 6 7 8 9 I0 Ii 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 owners in Park City, Deer Valley, Hawaii, Sun Valley. Those are the ones t.hat come to mind at the moment. Q Do you ever do ~ny consdlting work with advertising agencies? • A Yes, I do. Q What is your involvement in that type of consulting? A Typically the agency work relates to ~ discussing with the agency and the client how the creative execution can reflect th~ client's desired marketing strategies. Q consulted A which is which is I have And-what with? I have here in Salt also in Salt advertising agencies have you consulted Lake Lake had discussions with all those Do you consider yourself an marketing? A Yes. Q Do you consider yourself a~ advertising? A Yes.. Do you consider yourself an with Dunn Communications, City; Harris & Love, City, and Snedeker Group, organizations. expert in expert in expert in 14

1 2 3 4 5 6 7 8 9 i0 ii 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 communications? A Yes. Q Mass communications? A Mass communications and marketing communications which focuses more on the firm's decision-making, of mass A individual communications. Q So when you stated previously that been qualified as an expert in consumer does that fall under the communication? Consumer decisiqn-making would fall under consumer behavior. yourself also an you've auspices the general area referred to as Q So you would consider expert in consumer behavior? A Yes. Q Of marketing, advertising, consumer behavior, which have you qualified in court as an m~rketing and consumer communications. Those have been prior cases. consider yourself an expert in Sociology? expert before? A Advertising, behavior and mass all referenced in Q DO you psychology? A No. 15

1 2 3 4 5 6 7 8 9 i0 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Epidemiology? NO. Statistics? I have substantial would not offer myself training but as an Q Would that training fall category of behavioral statistics? A I'm not sure what you mean by you could rephrase that I might clarify. Q Or by saying you've had training statistics, do you just know how to read studies? in statistics, expert. under the that. If in the journ~l A My training in my Ph.D. program a~lowed me to conduct studies and to read the journal studies. Q I'm looking at your publications which includes books, journal publications, conference proceedings. Have you ever done any work that was specific to adolescents, and I mean in terms of marketing, advertising, communications? A Let me refresh my memory to see if any of my respondents were adolescents. Yes. Q Could you point that out to me? A Yes. -The arts marketing research stream represented by, under Journal Publications, the 16

1 2 3 4 5 6 7 8 9 i0 II 12 13 14 15 16 17 18 19 2O 21 22 23 24 third article, "The Consumption and the with Gary Bamossy. ~ Experiential Shaping of a Gary Bamossy Nature Of 'New Aesthetic'," was a doctoral student. That study focused on adolescents. Q And what was the nature of that study? A The nature of that study was to identify how adolescents the marketplace symphony. Are MR. publications? Q Conference MR. Proceedings, came to view artistic offerings like theatre, dance, opera, there any others? HELMS: Are.you just referring to (BY MS. COLEY) Yes. Which includes Proceedings and Research. HELMS: Publications, Conference Research, pretty mu~h everything. in his THE WITNESS: Right. There"s a study on page-- well, study may be not .thi correct word-- but on page 7 there's an article titled "An Anthropological Perspective on Consumer Research Issues." Q (BY MS. COLEY) And how did that include adolescents? • A That was written with an anthropologist, Dennis Heskel,• and the concept of that study was 17

1 2 3" 4 5 6 7 8 9 I0 ll 12 14 15 16 17 18 19 2O 21 22 23 24 25 that marketers can behavior by studying do in terms of their and production. And so it learn much about consumer people the way anthropologists household domestic consumptio~ included th~ whole family with a significant emphasis on children as part of the consumption decision-making process that households necessarily have to go through. But it was conceptual. We did not ask people questions, we did not generate data. So in that sense study would not be exactly right, but it is an article that considered that issue. Those would be the articles that included adolescents. Q On pagell of your Vita you list your professional service which includes a reviewer of various publications. .What is the difference between a reviewer and being on the editorial board? A The editorial board is a small group, typically from six to 12 individuals, who have been asked to give advice to the editor of the journal regarding editorial policy and philosophical direction of the journal. So it would be very much like a board of directors in a corporation. Q And what do you do as a reviewer? A As a reviewer, the editor sends you 18

! 2 3 4 5 6 7 8 9 I0 Ii 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 articles quality of the publication. Q And what A An ad hoc asked to do reviews individual who is not and asks you to glve your opinion about article and its worthiness for is an ad hoc reviewer is a by the editor, formally on review board. Q And you're of the Journal of Health A Yes, I am. Q What is journal? A I have not reviewed not want to say what it is. What generally does area? have to the Q 26 Expert that? A reviewer? reviewer that's but is an the editorial on the editorial review board Care Marketi~q? the philosophical purpose of that that lately so I would it deal with, what A The articles I have been. asked to review to do with marketing technology as it's applied health care industry. Next I had marked as Statement Exhibit in this case. Do you Did you prepare this expert 3 your Rule recognize statement? 19

1 2 3 4 5 6 7 8 9 I0 I! 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I prepared this statement in conjunction with the attorneys in the case. Q When did you start working preparation of this statement? A January. Q '96 or '97? A No, that couldn't be right. March. It would have been November want to go through this Q I and ask you some testify about. on the This is only or December '96. expert statement questions about what it says you'll It says in paragraph 2 that you will general testify about universally accepted models of consumer dec£sion-making. Are you going to talk about several different models or is there one basic model that you have in mind? with A Well, in terms of testifying, I'll testify respect to the questions that are asked. Q I understand that. MR. HELMS: Jennifer, are you just asking whether, in his mind there's more than ode model? Q (BY MS. COLEY) Yes. A There are many models of ~he consumer decision-making. Q Is there one generally accepted model that would apply best t.o consumer decisions about smoking 2O