EXHIBIT 10.3
BY HUBERT H. HUMPHREY, III,
ITS ATTORNEY GENERAL,
and
BLUE CROSS AND BLUE SHIELD
OF MINNESOTA,
Plaintiffs,
vs.
PHILIP MORRIS INCORPORATED,
R.J. REYNOLDS TOBACCO COMPANY,
BROWN & WILLIAMSON TOBACCO
CORPORATION, B.A.T. INDUSTRIES
P.L.C., BRITISH-AMERICAN TOBACCO
COMPANY LIMITED, BAT (U.K. &
EXPORT) LIMITED, LORILLARD
TOBACCO COMPANY, THE
AMERICAN TOBACCO COMPANY,
LIGGETT GROUP, INC., THE
COUNCIL FOR TOBACCO RESEARCH
U.S.A., INC. and THE TOBACCO
INSTITUTE, INC.,
Defendants.
SETTLEMENT AGREEMENT AND RELEASE
THIS SETTLEMENT AGREEMENT AND RELEASE ("Settlement Agreement") is made as of the date hereof,
by and among the parties hereto, as indicated by their signatures below, to settle and resolve with finality all
claims of BCBSM, Inc. d/b/a Blue Cross and Blue Shield of
Minnesota ("Blue Cross") relating to the subject matter of this action which have been or could have been
asserted by Blue Cross and Blue Shield of Minnesota.
WHEREAS, Blue Cross is a nonprofit health service plan corporation organized pursuant to Minnesota Statutes
Chapter 62C, and as such fulfills a variety of health related functions in the State of Minnesota;
WHEREAS, the general purposes of Blue Cross under its enabling legislation and its Articles of Incorporation is
"to make possible wide, economic and timely availability of hospital, medical surgical, dental and other health
services for the people of Minnesota and others" and "advance public health and the art and science of hospital,
medical and health care under the laws of the State of Minnesota;"
WHEREAS, Blue Cross in recognition and furtherance of its statutory mandate and charter, and the State of
Minnesota, through its Attorney General, Hubert H. Humphrey III, commenced this action on August 17, 1994,
asserting various claims for monetary and injunctive relief on behalf of Blue Cross and the State of Minnesota
against certain tobacco manufacturers and others as Defendants;
STATE OF MINNESOTA