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Privileged Document Codes


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	Privilege Code Keys American Tobacco Privilege Codes B&W Privilege Codes BAT Privilege Codes Lorillard Privilege Codes Philip Morris Privilege Codes RJ Reynolds Privilege Codes


	Privilege Log Glossaries BAT Glossary of Names Lorillard Glossary of Names Philip Morris Glossary of Names RJ Reynolds Glossary of Names


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About Privileged Documents

Seven (7) collections - Philip Morris, R.J. Reynolds, Lorillard, Multimedia, American Tobacco, Brown & Williamson, and British American Tobacco - include records of documents withheld from production due to claim(s) of attorney-client privilege (AC), work-product protection (WP/OWP), and joint-defense or common-interest privilege (JD/CI).

If a specific document has a status of "privileged", there will be no PDF or TIFF attached to the metadata record.

Each privileged document's record contains a code in the Document Status (st:) field that explains the type of privilege claim under which it was withheld from production. These codes and their corresponding definitions are listed below by company.

If a document is designated as "Formerly Privileged" on LTDL, the metadata record will contain indexing submitted by the tobacco companies when the document was finally released as well as the original indexing in brackets "[ ]".

If a specific document is designated as "privileged" but LTDL happens to have a copy of the actual document image, a link to the viewable document will be listed in the Related (related:) field.

Glossaries of names were provided by each company to give information about individuals mentioned in the privileged documents.

More about Documents Designated as Privileged or Confidential.

American Tobacco Company

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This key explains the abbreviations used for privilege claims by American Tobacco Company:
AC	Confidential communications exchanged between or among in-house or outside attorneys representing American Tobacco and employees of the client American, or consultants (or those assisting them) employed by American Tobacco, which were prepared for the purpose of seeking or rendering legal advice or seeking or providing confidential information in order to assist in the rendering of legal advice. Additionally, this category includes confidential documents which have been redacted or withheld because they contain, refer to or describe confidential attorney-client communications or the substance of such communications.
WP	Documents authored by American Tobacco employees or American Tobacco in-house or outside attorneys (or those assisting them) which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinion or other work product regarding various legal matters, including smoking and health matters, developments, research, or programs.
OWP	(Opinion Work Product) Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by B&W Tobacco, a representative of B&W Tobacco, the attorney, or a representative of the attorney and which contain counsel's mental impressions, opinions, conclusions or legal theories.
JD/CI	Confidential documents constituting, containing or reflecting communications, or the substance of same, between or among in-house or outside attorneys for American Tobacco and/or entities with which it shared common legal interest (e.g., tobacco companies, tobacco trade associations, or CTR) or between or among such attorneys and employees of entities with which American Tobacco shared common interests. Additionally, this category includes documents prepared by employees of in-house or outside attorneys representing (or those assisting them) entities sharing common interests with American Tobacco which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinions or other work product regarding various legal matters.

Brown and Williamson Tobacco Company

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This key explains the abbreviations used for privilege claims by Brown and Williamson Tobacco Company:
AC	Confidential communications exchanged between or among in-house or outside attorneys representing B&W Tobacco and employees of the client, or consultants (or those assisting them) employed by B&W Tobacco, which were prepared for the purpose of seeking or rendering legal advice or seeking or providing confidential information in order to assist in the rendering of legal advice. Additionally, this category includes confidential documents which have been redacted or withheld because they contain, refer to or describe confidential attorney-client communications or the substance of such communications.
WP	Documents authored by B&W Tobacco employees or B&W Tobacco in-house or outside attorneys (or those assisting them) which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinion or other work product regarding various legal matters, including smoking and health matters, developments, research, or programs.
OWP	(Opinion Work Product) Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by B&W Tobacco, a representative of B&W Tobacco, the attorney, or a representative of the attorney and which contain counsel's mental impressions, opinions, conclusions or legal theories.
JD/CI	Confidential documents constituting, containing or reflecting communications, or the substance of same, between or among in-house or outside attorneys for B&W Tobacco and/or entities with which it shared common legal interest (e.g., tobacco companies, tobacco trade associations, or CTR) or between or among such attorneys and employees of entities with which B&W Tobacco shared common interests. Additionally, this category includes documents prepared by employees of in-house or outside attorneys representing (or those assisting them) entities sharing common interests with B&W Tobacco which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinions or other work product regarding various legal matters.

British American Tobacco Privilege Codes

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This key explains some of the abbreviations used for privilege claims by the British American Tobacco Company:
AC	Confidential communications exchanged between or among in-house or outside attorneys. This category includes confidential documents which have been redacted or withheld because they contain, refer to or describe confidential attorney-client communications or the substance of such communications.
FWP	(Fact Work Product) Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by BAT, a representative of BAT, the attorney, or a representative of the attorney and which contain or reflect facts obtained by counsel or at the request of counsel.
OWP	(Opinion Work Product) Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by BAT, a representative of BAT, the attorney, or a representative of the attorney and which contain counsel's mental impressions, opinions, conclusions or legal theories.
JD/LP	Confidential documents constituting, containing or reflecting communications, or the substance of same, between or among in-house or outside attorneys for BAT and/or entities with which it shared common legal interest (e.g., tobacco companies, tobacco trade associations, etc) or between or among such attorneys and employees of entities with which BAT shared common legal interests.

Lorillard Privilege Codes

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To explain the codes used in Lorillard's Privilege Log Records, we have reprinted the information below from the Lorillard

document site.

Attorney-Client Privilege
Documents found in the following categories contain legal advice, requests for legal advice or services, or provide information in connection with the rendering of legal advice or services:
1A	Confidential communications from Lorillard employees to Lorillard counsel
1B	Confidential communications from Lorillard counsel to Lorillard employees
1C	Confidential communications between Lorillard counsel
1D	Confidential communications between Lorillard employees containing, or for purposes of obtaining, legal advice
2	Confidential communications between Lorillard employees or Lorillard counsel and the employees or counsel of an agent, confidential litigation consultant or informal consultative expert of Lorillard or another entity with a common legal interest
3A	Confidential communications between Lorillard counsel and the employees or counsel of another entity with a common legal interest
3B	Confidential communications between Lorillard employees and the employees or counsel of another entity with a common legal interest
Work Product
WP	Reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation or other adversarial proceedings and documents which contain or reflect counsel's (or counsel's agents) mental impressions, conclusions, opinions or legal theories concerning such matters

Philip Morris Privilege Codes

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To explain the codes used in Philip Morris's Privilege Log Records, we have reprinted the information below from the Philip Morris

document site.

Attorney-Client Privilege
Documents designated as attorney-client privileged ("AC") contain legal advice, requests for legal advice or services, or provide information in connection with the rendering of legal advice or services:
1A	Confidential communications from Philip Morris USA, Inc. employees to Philip Morris USA, Inc. counsel
1B	Confidential communications from Philip Morris USA, Inc. counsel to Philip Morris USA, Inc. employees
1C	Confidential communications between Philip Morris USA, Inc. counsel
1D	Confidential communications between Philip Morris USA, Inc. employees containing, or for the purposes of obtaining, legal advice
2	Confidential communications between employees or counsel and the employees or counsel of an agent, confidential litigation consultant, or informal consultative expert of Philip Morris USA, Inc. or another entity with a common interest
Work Product
Documents designated as work product protected ("WP") consist of reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by the client, a representative of the client, the attorney, or a representative of the attorney:
OWP	(Opinion Work Product) containing counsel's mental impressions, opinions, conclusions or legal theories
FWP	(Fact Work Product) containing facts obtained by counsel or at the request of counsel
Joint Defense
Documents designated as joint defense privileged ("JD") consist of documents containing legal advice, requests for legal advice or services, or provide information in connection with the rendering of legal advice or services and/or reports, statements, correspondence, memoranda or other documents prepared in anticipation of litigation by the client, a representative of the client, the attorney, or a representative of the attorney and other companies, their employees, their counsel and/or agents with a common interest or in a joint defense with Philip Morris USA Inc.:
3A	Confidential communications between Philip Morris USA, Inc. counsel and the employees or counsel of another entity with a common interest.
3B	Confidential communications between Philip Morris USA, Inc. employees and the employees or counsel of another entity with a common interest.

R.J. Reynolds Privilege Codes

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To explain the codes used in R.J. Reynolds's Privilege Log Records, we have reprinted the information below from the R.J. Reynolds

document site.

This key explains the abbreviations used for privilege claims by R.J. Reynolds Tobacco Company:
AC	Confidential communications exchanged between or among in-house or outside attorneys representing Reynolds and employees of the client Reynolds, or consultants (or those assisting them) employed by Reynolds, which were prepared for the purpose of seeking or rendering legal advice or seeking or providing confidential information in order to assist in the rendering of legal advice. Additionally, this category includes confidential documents which have been redacted or withheld because they contain, refer to or describe confidential attorney-client communications or the substance of such communications.
WP	Documents authored by Reynolds employees or Reynolds in-house or outside attorneys (or those assisting them) which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinion or other work product regarding various legal matters, including smoking and health matters, developments, research, or programs.
JD	Confidential documents constituting, containing or reflecting communications, or the substance of same, between or among in-house or outside attorneys for Reynolds and/or entities with which it shared common legal interest (e.g., tobacco companies, tobacco trade associations, or CTR) or between or among such attorneys and employees of entities with which Reynolds shared common interests. Additionally, this category includes documents prepared by employees of in-house or outside attorneys representing (or those assisting them) entities sharing common interests with Reynolds which were prepared in anticipation of or in connection with litigation and which contain or reflect analyses, summaries, mental impressions, conclusions, opinions or other work product regarding various legal matters.