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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`RAI STRATEGIC HOLDINGS, INC. and
`R.J. REYNOLDS VAPOR COMPANY
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`Case No. 1:20-cv-00393-LO-TCB
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`Plaintiffs and Counterclaim
`Defendants,
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`v.
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`ALTRIA CLIENT SERVICES LLC; PHILIP
`MORRIS USA INC.; and PHILIP MORRIS
`PRODUCTS S.A.
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`Defendants and Counterclaim
`Plaintiffs.
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`[PROPOSED] ORDER
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`Upon consideration of Counterclaim Plaintiffs Altria Client Services LLC, Philip Morris
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`USA Inc., and Philip Morris Products S.A.’s Motion to Compel Reynolds’ 30(b)(6) Deposition on
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`Topics 28, 54, and 78, for good cause shown, it is hereby ORDERED that the Motion to Compel
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`shall be, and hereby is, GRANTED. Counterclaim Defendants are ordered to, within three days
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`of the date of this order, (i) designate a corporate witness for Topics 28, 54, and 78, and (ii) make
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`Mr. Gilley available for a one-hour deposition on his conversation with Dr. Sullivan, Reynolds’
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`damages expert.
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`IT IS SO ORDERED this _______ day of April, 2021.
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`United States Magistrate Judge
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