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Bexon, Robert L.

US Fact Witness

Robert L. Bexon, President and CEO, Imperial Tobacco Company Limited ("ITL"), August 27, 2000 to present President and COO, ITL, July 4, 1999 to August 27, 2000 SECONDMENT TO Brown & Williamson ("B&W"): Senior Vice-President, Marketing & Sales, B&W, September 1, 1995 to July 4, 1999 (secondment approved by Don Brown, CEO and Chairman of the Board, ITL), Ulrich Herter (Managing Director, BAT plc), and Nicholas G. "Nick" Brookes (B&W CEO and Director Americas and Pacific ("AMPAC") Region for BAT)

Robert Bexon is expected to testify by deposition designation concerning 1) B&W and BATCo corporate conduct and positions, including corporate statements about smoking and health; the addictiveness of nicotine; marketing to youth and "low tar/low nicotine" cigarettes; 2) predicate acts constituting the pattern of racketeering activity through which B&W participated in the conduct, management, and operation of the affairs of the Enterprise, including B&W's and BATCo's marketing activities and company or industry knowledge regarding marketing and public statements regarding advertising, merchandising, and promotional activities; 3) B&W's and BATCo's marketing activities related to youth and "low tar/low nicotine" cigarettes; 4) company or industry knowledge regarding youth smoking issues and public statements concerning the voluntary restrictions or codes; and 5) claims about "low tar/low nicotine" cigarettes in the marketing of such cigarettes and efforts to market less hazardous cigarettes.

Source: United States' Factual Memorandum Pursuant to Order #470, Section V (tab 1)