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MOTLEY ASKS WIGAND ABOUT OTHER CIGARETTE ADDITIVES A. Acetaldehyde was an additive that was used.
Q. Additive that was used to boost nicotine effect; is that correct?
A. Acetaldehyde enhances the synergistic effect of nicotine and physiological effect. It is also well documented outside of the tobacco industry.
Q. So if you put that in there with nicotine, you are adding to whatever natural effect nicotine imparts; is that correct?
A. So to speak, yes.
Q. To your knowledge, did Brown & Williamson knowingly add this substance that I can't pronounce to its tobacco products? Did they know what they were putting in there?
MR. BEZANSON: Object to the form and repeat the instruction.
MR. MOTLEY:
Q. Did they know what they were putting in there?
A. Yes.
Q. In other words, additives were a matter of scientific interest to the companies; is that correct?
MR. BEZANSON: Object to the form.
A. Yes, sir.
MR. MOTLEY:
Q. But they had a law firm keeping track of it for them?
MR. BEZANSON: Object to the form.
A. The law firms serves as a central repository for interaction between tobacco companies and HHS. Covington & Burling also prepared what was considered white papers which looked at using outside technical resources to provide some expert or scientific opinions on various additives that were used by the industry for which the industry may or may not have had appropriate documentation.
MR. BEZANSON: Move to strike as nonresponsive and as having volunteered information not requested by the question but that strayed into attorney/client privilege matters. And, therefore, move to strike. And, again, repeat my instruction to the witness to refrain from disclosing any matters covered by attorney/client privilege.
MR. MOTLEY:
Q. Sir, to your personal knowledge, did Covington & Burling sometimes edit scientific information on additives?
A. Yes.
MR. BEZANSON: Same objections.
MR. MOTLEY:
Q. And now, this is an law firm, correct?
A. That is correct.
Q. Sir, do you know, are you familiar with the term called "document management," the management of documents?
A. Well, it has a number of contexts. I'm not exactly sure what you are asking.
Q. The context of keeping documents in foreign countries so federal agencies in the United States and lawyers and courts can't get access to them. That's what I mean.
A. I'm aware of that.
Q. Did that occur with Brown & Williamson and British-American Tobacco Company?
MR. BEZANSON: Object to the form and repeat the admonition and instruction and objection with respect to attorney/client privilege.
A. Yes.
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