EXHIBIT 10.1
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
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 STIPULATION
FOR ENTRY OF CONSENT JUDGMENT
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 the State of Minnesota relating to the subject matter of this action which have
been or could have been asserted by the State of Minnesota.
WHEREAS, the State of Minnesota, through its Attorney General Hubert H. Humphrey III, and Blue Cross and
Blue Shield of Minnesota, commenced this action on August 17, 1994, asserting various claims for monetary,
equitable and injunctive relief on behalf of the State of Minnesota and Blue Cross and Blue Shield of Minnesota
against certain tobacco manufacturers and others as Defendants;
WHEREAS, the Defendants have denied each and every one of Plaintiffs' allegations of unlawful conduct or
wrongdoing and have asserted a number of defenses to Plaintiffs' claims, which defenses have been contested by
Plaintiffs;
WHEREAS, the parties hereto wish to avoid the further expense, delay, inconvenience, burden and uncertainty
of continued litigation of this matter (including appeals from any verdict), the State of Minnesota and the Settling
THE STATE OF MINNESOTA, Case Type: Other Civil
BY HUBERT H. HUMPHREY III, Court File No. C1-94-8565
ITS ATTORNEY GENERAL,
and resolve with f