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09/10/97 WED 11:50 FAX 202 514 8071 CIVIL OAAG cc: Bruce R/Bruce L 002 Tobacco- legal itsues TOBACCO U.S. Department of Justice Class Actions Office of the Assistant Attorney General PEOMITION POLICE Civil Division FRITZIA George Jordan Phillips 950 Pennsylvania Ave., N.W., Room 3143 Counselor to the Assistant Attorney General Washington, D.C. 20530 (202) 514-5713 Fax (202) 514-8071 September 10, 1997 VIA FACSIMILE (202) 456-2878 Ms. Elena Kagan Deputy Assistant to the President for Domestic Policy Old Executive Office Building, Room 218 Washington, D.C. 20501 RE: Class Action Developments Dear Ms. Kagan: This letter is intended to update you about the status of the plaintiffs' success in lawsuits against tobacco companies in being certified as class actions. Since out briefing, the plaintiffs in the Pennsylvania case dropped the claims related to paying for treatment for smoking related diseases and restricted them to requiring the injunctive relief of just medical monitoring so that the federal court has now tentatively certified this action as a class action. (See attached article.) In our earlier briefing we reported that a Pennsylvania federal district court had denied a requested class action. Arch V. American Tobacco Co., 1997 WL 312112 (E.D. Pa. 1997). In Barnes V. American Tobacco Co., 1997 U.S. Dist. LEXIS 12814 (E.D. Pa. 8/22/97), the district court granted a motion to certify a narrower class of smokers than the proposed class in Arch (although the case caption has changed, Barnes and Arch are the same civil actions). This is the first time that a federal district court has certified a class of smokers against the tobacco industry. The Barnes plaintiffs have dropped all the previous claims against the tobacco companies except for a claim for medical monitoring. The counts for negligence, intentional exposure to a hazardous substance, and strict products liability were excluded from the latest complaint. In light of these changes, the district court certified a class of all current residents of Pennsylvania who are cigarette smokers as of December 1, 1996, and who began smoking before age 19, while they were residents of Pennsylvania.