Letter from the Corporate Affairs Director
Imperial Tobacco Group PLC (TB 13B)
Thank you for your letter of 21 December 1999
to Gareth Davis. I have been asked to respond on behalf of Imperial.
Neither I nor my colleagues are familiar with
the content of the BAT archive at Guildford beyond that it contains
documents relating to smoking and health issues. We are therefore
unsure what material you regard to be analogous to material in
the BAT archive.
However, in anticipation of potential legal
proceedings, we collected from our premises throughout the UK
an archive of Imperial documents which are stored in folders.
Most of the documents in this archive date from 1950 onwards but
some go back to the last century. This has been a massive collection
exercise and has produced a vast volume of documents. We have
tried to make this volume of documents manageable by identifying
those folders of documents in the archive which are likely to
be immaterial or only marginally relevant to any litigation, with
the intention that eventually all of the documents in the remaining
folders should be entered on a database. The process of creating
this database is currently only partially complete.
We attach an index of 18,946 folders from our
archive. This is a complete listing of the folders currently in
the archive other than approximately 3,000 folders which have
yet to be listed and some pre-1981 folders which our lawyers have
identified as privileged. The 18,946 folders contain, we estimate,
approximately 3.8 million pages of documents and the 3,000 folders
about 600,000 pages.
For the purposes of the English litigation,
it was agreed that Imperial should give discovery of their documents
which were relevant to the issues in the litigation in two tranches:
up to 1971 and 1972-80 (inclusive). By the time that the litigation
ended, we had served one list of documents for each of these two
periods. Although these lists would have needed to be supplemented
as a result of our continuing work had the litigation gone to
trial, they contain a substantial majority of the relevant documents.
I enclose indices of the documents which were contained in these
lists and provided to the plaintiffs. These documents amount in
total to approximately 210,000 pages.
We also have copies of TMA documents. However,
we understand that Gallaher will be providing you with an index
of TMA documents up to 1996.
We would be happy to provide you with copies
of the enclosed indices in electronic format if that would assist
you.
10 January 2000
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