Filing # 90828469 E-Filed 06/10/2019 01:03:41 PM
`
`IN THE CIRCUIT COURT OF THE 17TH
`JUDICLAL CIRCUIT IN AND FOR
`
`BROWARD COUNTY, FLORIDA
`
`COMPLEX LITIGATION UNIT
`
`CASE NO. 08-80000
`
`JUDGE MARTIN BIDWILL
`
`IN RE: ENGLE PROGENY CASES
`
`TOBACCO LITIGATION
`
`Pertains to.‘ Jacqueline Mechelle Blackwooa’
`As Personal Representative of the
`Estate ofMary Cooper
`
`Case No. .' 08-026350
`
`/
`
`PLAINTIFF’S NOTICE OF FILING EXPERT WITNESS LIST
`
`Plaintiff, JACQUELINE MECHELLE BLACKWOOD, as Personal Representatives of
`
`the Estate of MARY COOPER, by and through undersigned counsel, and herewith files this
`
`Expert Witness List pursuant to the Florida Rules of Civil Procedure.
`
`Plaintiff explicitly reserves the right to supplement this list as discovery is ongoing.
`
`Plaintiff also reserves the right to supplement/amend this list prior to trial.
`
`All of the opinions expressed by each expert are held Within a reasonable degree of
`
`probability.
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/10/2019 01:03:40 PM.****
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 10th day of June 2019, the foregoing document was served this
`
`day on all counsel of record identified on the attached Service List.
`
`SCHLESINGER LAW OFFICES, P.A.
`Attorney for Plaintiffs
`1212 Southeast Third Avenue
`
`Fort Lauderdale, FL 33316
`(954) 320—9507
`
`By: _s/J0nathan Gdanski
`Jonathan R. Gdanski
`
`Florida Bar No.: 0032097
`
`

`

`PLAINTIFF’S EXPERT WITNESS DISCLOSURES
`
`K. Michael Cummings, Ph.D., MPH
`Medical University of South Carolina Hollings Cancer Center
`86 Jonathan Lucas Street
`
`Charleston, South Carolina 29425
`
`the Medical
`Dr. Cummings is Professor of Psychiatry and Behavioral Sciences at
`University of South Carolina. He is engaged in research regarding cancer prevention and
`control, with an interest in understanding factors that influence tobacco use behaviors.
`Dr. Cummings will comment on and discuss the conduct of each defendant over the last
`twenty years. Dr. Cummings will also comment on and discuss the current conduct of each
`Defendant.
`
`Dr. Cummings will testify on the general subject matters of: tobacco industry actions as
`
`they relate to issues of smoking and health and history; tobacco use epidemiology including
`
`smoking initiation, addiction, and cessation; and health risks from smoking. He will testify
`
`on the subject of tobacco industry actions including an analysis of the public and private
`
`statements of the tobacco industry and their affiliated organizations; industry history,
`
`including internal corporate knowledge and public communications; and the role of the
`
`Tobacco Industry Research Committee (TIRC), Council for Tobacco Research (CTR), and
`
`the Tobacco Institute (TI). His testimony will be based on his own original research,
`
`internal industry documents, and interviews with public health experts, scientists and
`
`tobacco industry employees.
`
`The subject of tobacco use epidemiology includes factors that influence smoking-related
`
`behaviors including initiation of tobacco use, brand choice, the influence of product
`
`marketing on brand choice and smoking behaviors, the influence of product design features
`
`on smoking behaviors, consumer knowledge and risk perceptions related to smoking, and
`
`the factors that influence smoking cessation including nicotine addiction. His testimony
`
`will be based on his own original research, internal industry documents, and interviews
`
`with public health experts, scientists and tobacco industry employees. The subject matter
`
`includes aspects of cigarette design relevant to the foregoing subject areas and documents
`
`relating to the foregoing subject areas. Dr. Cummings' opinions and the grounds for those
`
`opinions have been disclosed through more than 50 reports, depositions, and other
`
`testimony he has given in past tobacco litigation.
`
`Robert Proctor, PH.D.
`
`Professor of the History of Science
`Stanford University
`
`Subject Matter: History — Medical History — Cigarette History
`
`

`

`Dr. Proctor will testify on the general subject matter of history with an emphasis on the
`history of science and of knowledge more generally as it relates to the issues in this action.
`This subject area generally includes the history of tobacco production and consumption,
`including cigarette consumption; the evolution of scientific understanding of the hazards
`of smoking cigarettes, including how, why, and when particular segments of society
`(industry, public health, scientific community, general public) came to possess given
`aspects of such knowledge; the different methods involved in the discovery of smoking-
`related diseases; historical forces responsible for the growth of cigarette consumption; how,
`when, and by whom lung cancer came to be traced to cigarettes; the tobacco industry's
`knowledge of hazards associated with cigarette smoking and its misrepresentations to the
`public; the history of youth marketing, cigarette design, and of cigarette warnings; the
`timing, manner, and significance of cigarette industry admissions and revelations regarding
`the hazards associated with smoking cigarettes; the likely historical impact of different
`behaviour by the cigarette industry with respect to the foregoing issues, including health
`impacts; aspects of cigarette design, marketing, and promotion relevant to all foregoing
`subject areas; and documents relating to all foregoing subject areas.
`
`Dr. Proctor will comment on and discuss the conduct of each defendant over the last twenty
`years. Dr. Proctor will also comment on and discuss the current conduct of each Defendant,
`and each Defendant’s current regulatory environment.
`
`3.
`
`Fredrick Anthony Raffa, Ph.D.
`17 S. Ocseola Ave, Ste. 200
`
`Orlando, FL 32801
`
`Subject Matter: Economy
`
`Dr. Raffa is expected to testify in the area of economics. Dr. Raffa’s testimony will be
`based on his background, training and experience, review of expert reports and data, and
`all other materials relevant and necessary or which become available. Dr. Raffa will discuss
`the financial status of each defendant.
`
`Generic Experts
`
`Plaintiff reserves the right to, and anticipates utilizing, any generic expert deposition taken
`and cross noticed in Hillsborough, Escambia and Broward County, including but not limited to the
`discovery and trial depositions of:
`
`4.
`
`NEAL BENOWITZ, M.D.
`
`Opinion Type.‘ Generic
`
`Dr. Benowitz will testify on the subject matter of addiction. The subject area generally
`includes the meaning of addiction;
`the manner of assessing and diagnosing addiction;
`distinguishing addiction from other habits; distinguishing drug addiction from other addictions;
`the reasons people become and remain addicted and the different ways in which different people
`become and remain addicted; the physiological mechanism of addiction; the addictive qualities of
`
`

`

`nicotine; the means of addiction to cigarettes containing nicotine; compensation; the addictive
`qualities of cigarettes containing nicotine vs. other nicotine delivery systems; the highly-designed
`cigarette as a nicotine delivery (addiction-sustaining) device; nicotine manipulation; cessation and
`the significance of cessation attempts; the history of the tobacco industry's knowledge and conduct
`relating to these issues and to nicotine and addiction generally; aspects of cigarette design and
`promotion relevant to all foregoing subject areas; and documents relating to all foregoing subject
`areas.
`
`Dr. Benowitz's opinions and the grounds for those opinions have been disclosed through
`more than 30 reports; depositions; and other testimony he has given in past tobacco litigation;
`including; purely by way of example; his deposition and/or trial testimony in the following cases;
`among many others:
`
`Engle vs. RJR, et al.; Fla. Dade County Circuit Court Case No. 94-08273 CA.
`
`State of Florida vs. American Tobacco Co.; et al.; Fla. Palm Beach County Circuit
`Case No. CL-95-1466.
`
`United States of America vs. Philip Morris USA; Inc.; et al.; US. District Court; District
`of Columbia Case No. 99-CV-02496.
`
`Local No. 17 Bridge & Iron Workers Ins. Fund v. Philip Morris; Inc.; et al.; US. District
`Court; ND. Ohio Case No. 1:97cv1422.
`
`Boeken v. Philip Morris; Inc.; et al.; Superior Court; Los Angeles County; Cal. Case No.
`BC226593.
`
`Schwarz vs. Philip Morris USA; Inc.; et al.; Circuit Court; Multnoma County; Ore. Case
`No. 0002-01376.
`
`A copy of Dr. Benowitz's CV has been furnished recently in Engle Progeny Tobacco
`litigation to all defendants in this action. However; the Plaintiff will immediately produce another
`copy of his CV at the request of any party.
`
`5.
`
`DAVID BURNS, M.D.
`
`Opinion Type.‘ Generic
`
`Dr. Burns will testify as needed on all aspects of smoking and health. The subject area
`generally includes pulmonary and cardiovascular anatomy and physiology and disease process and
`causation; the causal link between smoking and lung disease (including cancer and COPD);
`including the relative knowledge and sophistication over time of the public; public health
`community; and the cigarette industry regarding same; the relevance and potential contribution of
`non-smoking factors and lung disease (including cancer and COPD);
`including the relative
`knowledge and sophistication over time of the public; public health community; and the cigarette
`industry regarding same;
`related epidemiological
`topics; debate within the public health
`community regarding the health effects of smoking; including the cigarette industry's internal
`
`

`

`knowledge and its contribution to or other impact upon the debate; the history of tobacco and
`cigarette production, including their role in and effect upon public health issues; the role of the TI;
`TIRC; and CTR in relation to smoking and health, including their contribution to and impact upon
`knowledge and debate regarding the health effects of cigarettes within the public health field; youth
`initiation and youth marketing efforts by the industry; the design; manufacture; testing; marketing;
`and health effects of low-tar or "light" cigarettes and low-tar or "light" cigarette campaigns;
`carcinogenicity of cigarette smoke; all aspects ofnicotine addiction and smoking cessation; public
`education and tobacco control; including industry contributions to and interference with such
`efforts; economics of the tobacco industry; all Surgeon General reports and industry responses to
`Surgeon General reports; the impact on the public health field of the industry's fraud and deceit;
`industry advertising over time; aspects of cigarette design and promotion relevant to all foregoing
`subject areas; and documents relating to all foregoing subject areas.
`
`Dr. Bums' opinions and the grounds for those opinions have been disclosed through more
`than 50 reports; depositions; and other testimony he has given in past tobacco litigation; including;
`purely by way of example; his deposition and/or trial testimony in the following cases; among
`many others:
`
`Engle vs. RJR, et at., Fla. Dade County Circuit Court Case No. 94-08273 CA.
`United States ofAmerica vs. Philip Morris USA, Inc., et al., US. District Court;
`D.D.C. Case No. 99-CV-02496.
`
`Falise v. American Tobacco Co., et al., US. District Court; E.D.N.Y. Case No. 99-
`7392.
`
`Whiteley v. Raybestos-Manhattan, Inc., Superior Court; San Francisco County; Cal.
`Case No. 303184.
`
`Schwarz vs. Philip Morris USA, Inc., et al., Circuit Court; Multnoma County; Ore.
`Case No. 0002-01376.
`
`Williams vs. Philip Morris, Inc., et al., Circuit Court; Multnoma County; Ore.; Case
`No. 9705-03957.
`
`A copy of Dr. Bums' CV has been furnished recently in Engle Progeny Tobacco litigation
`to all defendants in this action. However; the Plaintiff will immediately produce another copy of
`his CV at the request of any party.
`
`6.
`
`K. MICHAEL CUMMINGS, Ph.D., MPH
`
`Opinion Type.‘ Generic
`
`Dr. Cummings will testify on the general subject matters of tobacco industry actions as
`
`they relate to issues of smoking and health and history; and tobacco use epidemiology including
`
`smoking initiation; addiction; and cessation; as well as health risks from smoking. The subject of
`
`tobacco industry actions including an analysis of the public and private statements of the tobacco
`
`

`

`industry and their affiliated organizations, industry history, including internal corporate knowledge
`
`and public communications including the role of the Tobacco Industry Research Committee
`
`(TIRC), Council for Tobacco Research (CTR), and the Tobacco Institute (TI). His testimony will
`
`be based on his own original research, internal industry documents, and interviews with public
`
`health experts,
`
`scientists and tobacco industry employees. The subject of tobacco use
`
`epidemiology includes factors that influence smoking-related behaviors including initiation of
`
`tobacco use, brand choice, the influence of product marketing on brand choice and smoking
`
`behaviors, the influence of product design features on smoking behaviors, consumer knowledge
`
`and risk perceptions related to smoking, and the factors that influence smoking cessation including
`
`nicotine addiction. His testimony will be based on his own original research, internal industry
`
`documents, and interviews with public health experts, scientists and tobacco industry employees.
`
`The subject matter includes aspects of cigarette design relevant to the foregoing subject areas and
`
`documents relating to the foregoing subject areas.
`
`Dr. Cummings' opinions and the grounds for those opinions have been disclosed through
`
`more than 50 reports, depositions, and other testimony he has given in past tobacco litigation,
`
`including, purely by way of example, his deposition and/or trial testimony in the following cases,
`
`among many others:
`
`Engle vs. RJR, el‘ al., Fla. Dade County Circuit Court Case No. 94-08273 CA.
`State of Florida vs. American Tobacco Co.,
`el‘ al., Fla. Palm Beach County Circuit
`Case No. CL-95-1466.
`
`Falise v. American Tobacco Co., el‘ al., US. District Court, B.D.N.Y. Case No. 99-
`7392.
`
`Bullock v. Philip Morris, Inc., et al., Superior Court, Los Angeles County, Cal., Case
`No. BC249471.
`
`Allen v. RJ Reynolds Tobacco Co., el‘ al., US. District Court, S.D. Fla. Case No.01-
`4319-CIV-K1NG.
`
`Reller v. Philip Morris, Inc., et al., Superior Court, Los Angeles County, Cal. Case
`No. BC261796.
`
`A copy of Dr. Cummings' CV has been fumished recently in Engle Progeny Tobacco
`litigation to all defendants in this action. However, the Plaintiff will immediately produce another
`copy of his CV at the request of any party.
`
`Dr. Cummings will appear live or by video, and he will also discuss current conduct of the
`companies over the last twenty years.
`
`

`

`7.
`
`WILLIAM A. FARONE, Ph.D.
`
`Opinion Type.‘ Generic
`
`Dr. Farone, former Director of Applied Research for Defendant Philip Morris, will testify
`regarding cigarette design, industry knowledge underlying and informing that design, and the
`effect of cigarette smoke upon smokers; the chemistry of cigarettes and cigarette smoke as it relates
`to addiction and cancer causation; pharmacology of nicotine and nicotine substitutes; state of the
`art regarding knowledge of Philip Morris and cigarette design, smoking and health; knowledge
`that Philip Morris had regarding consumer knowledge; additives in their chemistry;
`toxic
`substantives and their relationship to disease; marketing and advertising of cigarettes; Defendants'
`exploitation of their understanding of the cigarette manufacturing process, the components of a
`cigarette, and smoking behavior, in order to sell cigarettes; industry recognition at the time it
`denied that cigarette smoking caused disease, that evidence linking smoking and disease was
`sufficient to conclude scientifically that inhaling cigarette smoke was a cause of disease; industry
`knowledge that cigarettes are addictive and that nicotine is the agent in cigarette smoke primarily
`responsible for the addiction, and that it designed cigarettes accordingly; design aspects of "light"
`and low-tar cigarettes; ammoniation; compensation/compensatory smoking; the role of tobacco
`blends, additives, and manufacturing/processing methods in increasing the danger of developing
`smoking-related disease; the industry's failure to perform certain biological research and testing
`bearing on the safety of the products; Defendants'
`research and development activities
`demonstrating a substantial understanding of which chemicals in cigarettes are likely to contribute
`to the harms of smoking; Defendants' failure to test or incorporate harm-reducing technologies;
`Defendants' obfuscation of cigarette design and technology of cigarettes and cigarette smoke,
`including their harm.
`
`Dr. Farone's opinions and the grounds for those opinions have been disclosed through
`numerous reports, depositions, and other testimony he has given in past tobacco litigation,
`including, purely by way of example, his deposition and/or trial testimony in the following cases,
`among many others:
`
`Engle vs. RJR, et al., Fla. Dade County Circuit Court Case No. 94-08273 CA.
`United States ofAmerica vs. Philip Morris USA, Inc., et al., US. District Court,
`D.D.C. Case No. 99-CV-02496.
`
`Boeken v. Philip Morris, Inc., et al., Superior Court, Los Angeles County, Cal. Case No.
`BC226593.
`
`Falise v. American Tobacco Co., et al., US. District Court, E.D.N.Y. Case No. 99-7392.
`
`Whiteley v. Raybestos-Manhattan, Inc., Superior Court, San Francisco County, Cal. Case
`No. 303 184.
`
`Williams vs. Philip Morris, Inc., et at., Circuit Court, Multnoma County, Ore. Case No.
`97 05- 03957.
`
`Eastman vs. Brown & Williamson Tobacco Co., et al., Circuit Court for Pinellas County,
`Fla. Case No. 97-5968-CI—1 1.
`
`

`

`Bullock v. Philip Morris, Inc, et al., Superior Court, Los Angeles County, Cal. Case No.
`BC249471.
`
`A copy of Dr. Farone's CV has been furnished recently in Engle Progeny Tobacco litigation
`to all defendants in this action. However, the Plaintiff will immediately produce another copy of
`his CV at the request of any party.
`
`8.
`
`JACK E. HENNINGFIELD, Ph.D.
`
`Opinion Type.‘ Generic
`
`Dr. Henningfield will testify on the general subject matters of cigarette design; behavioral
`pharmacology; addiction; industry knowledge; and public/health community knowledge. These
`subject matters generally include aspects of cigarette design related to its addictiveness, including
`the cigarette as a nicotine delivery device and how cigarette design contributes to a smoker's
`addiction; the interface between cigarette and smoker; how the design contributes to deception of
`cigarettes about tar and nicotine exposures; the history of the foregoing (including the creation and
`sustenance of an addicted consumer market), which includes the history of industry knowledge;
`the impact on the public health community of industry deception and withholding of knowledge;
`addiction, including generally including the meaning of addiction; the manner of assessing and
`diagnosing addiction; distinguishing addiction from other behaviors and diseases; the reasons
`people become and remain addicted and the different ways in which different people become and
`remain addicted; the physiological mechanisms of addiction; the addictive qualities of nicotine;
`the means of addiction to cigarettes containing nicotine; compensation; the addictive qualities of
`cigarettes containing nicotine vs. other nicotine delivery systems; the highly-designed cigarette as
`a nicotine delivery (addiction-sustaining) device; nicotine manipulation; cessation and the
`significance of cessation attempts; the history of the tobacco industry's knowledge and conduct
`relating to these issues and to nicotine and addiction generally; aspects of cigarette design and
`promotion relevant to all foregoing subject areas; and documents relating to all foregoing subject
`areas.
`
`Dr. Henningfield's opinions and the grounds for those opinions have been disclosed
`through dozens of expert reports, depositions, and other testimony in past tobacco litigation,
`including, purely by way of example, his deposition and/or trial testimony in the following cases:
`
`State ofFlorida vs. American Tobacco Co., et al., Fla. Palm Beach County Circuit
`Case No. CL-95-1466.
`
`United States ofAmerica vs. Philip Morris USA, Inc., et al., US. District Court, D.D.C.
`Case No. 99-CV-02496.
`
`Grinnell v. American Tobacco Co., District Court of Jefferson County, Tex Case No.
`E-122-878.
`
`Scott v. American Tobacco Co., et al., Civil District Court, Orleans Parish, La. 96-8461.
`State of Washington v. American Tobacco Co., et al., Superior Court of King County,
`Wash. Case 96-2-15056 SEA.
`
`

`

`Ferlanti v. Liggett Group, Inc. et al., Circuit Court of Broward County, Fla. Case No.
`03-21697 (19).
`
`A copy of Dr. Henningfield’s CV has been furnished recently in Engle Progeny Tobacco
`litigation to all defendants in this action. However, the Plaintiff will immediately produce another
`copy of his CV at the request of any party.
`
`9.
`
`LOUIS KYRIAKOUDES, Ph.D.
`
`Opinion Type.‘ Generic
`
`Dr. Kyriakoudes will testify on the general subject matter of history and demography. This
`subject area generally includes the history of tobacco production and consumption, including
`cigarette consumption; public knowledge and perception over time of the health risks of cigarette
`smoking; cigarette advertising and disinformation and their impact over time on public perception
`of cigarettes and smoking; cigarette smoking as a cultural phenomenon, including social smoking
`patterns, "common knowledge" and uncertainty regarding smoking hazards, including addiction,
`and the cigarette industry's role in creating, fostering, and maintaining same; public perceptions of
`aspects of cigarette design and industry promotion activities relevant to all foregoing subject areas;
`and documents relating to all foregoing subject areas.
`Dr. Kyriakoudes’ opinions and the grounds for those opinions have been disclosed through
`dozens of expert reports, depositions, and other testimony in past tobacco litigation, including,
`purely by way of example, his deposition and/or trial testimony in the following cases:
`Boerner vs. Brown & Williamson Tobacco Co., US. District Court, B.D. Ark. Case No.
`NO-LR-C-98-427.
`
`Eastman vs. Brown & Williamson Tobacco Co., el‘ al., Circuit Court for Pinellas County,
`Fla. Case No. 97-5968-CI—1 1.
`
`Ferlanti v. Liggett Group, Inc. et al., Circuit Cour t of Broward County, Fla. Case No.
`03-21697 (19).
`Hall v. RJ Reynolds Tobacco Corp, Circuit Court of Hillsborough County, Fla. Case
`No. 00- 061.
`
`Mash vs. Brown & Williamson Tobacco Corp, US. District Court, B.D. Mo. Case
`No. 4:03CV0485TCM.
`
`A copy of Dr. Kyriakoudes’ CV has been furnished recently in Engle Progeny Tobacco
`litigation to all defendants in this action. However, the Plaintiff will immediately produce another
`copy of his CV at the request of any party.
`
`10.
`
`ROBERT N. PROCTOR, Ph.D.
`
`Opinion Type.‘ Generic
`
`Dr. Proctor will testify on the general subject matter of history with an emphasis on the
`history of science and of knowledge more generally as it relates to the issues in this action. This
`subject area generally includes the history of tobacco production and consumption, including
`cigarette consumption;
`the evolution of scientific understanding of the hazards of smoking
`cigarettes, including how, why, and when particular segments of society (industry, public health,
`
`

`

`scientific community, general public) came to possess given aspects of such knowledge; the
`different methods involved in the discovery of smoking-related diseases; historical forces
`responsible for the growth of cigarette consumption; how, when, and by whom lung cancer came
`to be traced to cigarettes; the tobacco industry's knowledge of hazards associated with cigarette
`smoking and its misrepresentations to the public; the history of youth marketing, cigarette design,
`and of cigarette warnings; the timing, manner, and significance of cigarette industry admissions
`and revelations regarding the hazards associated with smoking cigarettes; the likely historical
`impact of different behavior by the cigarette industry with respect to the foregoing issues, including
`health impacts; aspects of cigarette design, marketing, and promotion relevant to all foregoing
`subject areas; and documents relating to all foregoing subject areas.
`
`Dr. Proctor's opinions and the grounds for those opinions have been disclosed through more
`than a dozen of expert reports, depositions, and other testimony in past tobacco litigation,
`including, purely by way of example, his deposition and/or trial testimony in the following cases:
`United States ofAmerica vs. Philip Morris USA, Inc., et al., US. District Court,
`District of Columbia Case No. 99-CV-02496.
`
`Local No. 17 Bridge & Iron Workers Ins. Fund v. Philip Morris, Inc., et al., US. District
`Court, ND. Ohio 1:97cv1422.
`Ferlanti v. Liggett Group, Inc. et al, Circuit Court of Broward County, Fla. Case No. 03-
`21697 (19).
`
`A copy of Dr. Proctor's CV has been furnished recently in Engle Progeny Tobacco
`litigation to all defendants in this action. However, the Plaintiff will immediately produce another
`copy of his CV at the request of any party.
`
`Corporate Representatives
`
`11. Michael F. Borgerding, Ph.D.
`
`12.
`
`Nicholas George Brooks
`President and CEO of Brown & Williamson
`
`By Deposition
`
`13.
`
`Lawrence Bruff
`
`By Deposition
`
`14. William Ian Campbell
`President/ CEO of Philip Morris USA, Inc.
`By Deposition
`
`15.
`
`Cathy Lynn Ellis
`Director of Research at Philip Morris USA, Inc.
`By Deposition
`
`1 The Plaintiff will provide, at the appropriate time, deposition designations for each witness the Plaintiff intends
`on calling to testify through deposition testimony.
`
`

`

`16.
`
`Benjamin Few
`By Deposition
`
`17.
`
`James Figlar
`
`18.
`
`Charles D. Garner, Ph.D.
`
`19.
`
`Christy Lee Garner
`
`20.
`
`Robert F. Gertenbach
`
`Retired President of the Council for Tobacco Research By Deposition
`
`21.
`
`Dr. Paul M. Gross
`
`By Deposition
`
`22. Milton E. Harrington
`By Deposition
`
`23.
`
`Robert K. Heiman
`
`By Deposition
`
`24.
`
`James Wesley Johnston
`CEO of R. J. Reynolds Tobacco Company
`By Deposition
`
`25.
`
`Leonard Jones
`
`26.
`
`Horace R. Kornegay
`President of the Tobacco Institute
`
`By Deposition
`
`27.
`
`Bennett S. Lebow
`
`President and Chief Executive Officer for Brooke Group, parent company of
`Liggett Group Ltd., Inc
`By Deposition
`
`28.
`
`James J. Morgan
`President and Chief Executive Officer of Philip Morris
`By Deposition
`
`29.
`
`Daniel Provost
`
`By Deposition
`
`1 The Plaintiff will provide, at the appropriate time, deposition designations for each Witness the Plaintiff intends
`on calling to testify through deposition testimony.
`
`

`

`30.
`
`Thomas Edwin Sandefur, Jr.
`Chairman and CEO of Brown & Williamson Tobacco Company
`By Deposition
`
`31.
`
`Andrew Schindler
`
`32.
`
`Alexander Spears
`
`33.
`
`Andrew Tisch
`
`34.
`
`John Woods
`
`By Deposition
`
`35.
`
`36.
`
`Any and all expert witness listed by any other party in this action.
`
`Plaintiff reserves the right to amend, supplement, or otherwise alter this Expert Witness
`List in accordance with Florida Law.
`
`

`

`w
`Cooper v. RJ. Reynolds Tobacco Co., et al.
`
`Eric L. Lundt, Esq.
`GRAY | ROBINSON
`401 E. Las Olas Blvd., Ste. 1000
`
`Fort Lauderdale, FL 33301
`eric.lundt@gray-robinson.com
`Telephone: (954) 761-8111
`Fax: (954) 761-8112
`Attorney For: R.J. Reynolds Tobacco Company
`
`Stephanie E. Parker, Esq.
`John F. Yarber, Esq.
`
`John M. Walker, Esq.
`JONES DAY
`
`1420 Peachtree Street, NE.
`Suite 800
`
`Atlanta, GA 30309
`preichert@jonesday.com
`Phone: (404) 521—3939
`Fax: (404) 581-8330
`Attorney For: R.J. Reynolds Tobacco Company
`
`Andrew S. Brenner, Esq.
`Bruce A. Weil, Esq.
`BOIS, SCHILLER & FLEXNER LLP
`100 Southeast 2 Street, Suite 2800
`
`Miami, FL 33131
`Phone: (305) 539-8400
`Fax: (305) 539-1307
`PMUSA@bsfllp.com
`bweil@bsfllp.com
`mperez@bsfllp.com
`Attorney for: Phillip Morris USA Inc.
`
`