Alexander Spears is the Chairman and Chief Executive Officer of Lorillard Tobacco Company. Spears spent most of his life at Lorillard, having joined the company after he graduated from college in 1959.

State of Texas v. The American Tobacco Co., et. al.

July 24, 1997

Edward Westbrook: "Dr. Spears are you familiar with the statistics stating that approximately 3,000 teenagers start smoking every day?

Spears: "I've seen the numbers in the press recently. That's all I have."

Westbrook: "What do your marketing people tell you about that?"

Spears: "Nothing that I can recall."

Westbrook: "Have you not asked them "Is this true or not true?"

Spears: "No."

Westbrook: "Never?"

Spears: "I don't believe we've made this study."

Westbrook: "Is it any interest to you whether 3,000 teenagers start smoking everyday?"

Spears: "It certainly has not been part of our strategy and therefore I would say it has not been of interest from a marketing perspective."

State of Florida v. American Tobacco Co.

August 13, 1996 to August 14, 1996

Motley: "If I asked you to a reasonable degree of scientific probability, in your opinion has smoking cigarettes ever caused a single case of lung cancer in an American, what would your answer be?"

Spears: "I don't know."

Motley: "You don't know whether it has?"

Spears: "I don't know."

Motley: "How many cigarettes a year does your company manufacture?"

Spears: "Currently?"

Motley: "Yes."

Spears: "About 40 billion."

Motley: "Forty billion?

Spears: "Forty billion."

Motley: "So you continue to turn out 40 billion cigarettes a year not knowing whether cigarette smoking causes lung cancer; is that correct?"

Spears: "That's the same true-- that's true of any disease, or most of these chronic diseases. You don't know what causes a disease."

Motley: "So you continue to sell 40 billion cigarettes a year, not knowing whether or not it causes heart disease?"

Spears: "That's correct."

Motley: "You continue to manufacture and sell 40 billion cigarettes a year, not knowing whether it causes emphysema?"

Spears: "That's correct."

Motley: "You continue to sell and manufacture and sell 40 billion cigarettes a year saying you don't-- strike that. If it were--- if you were to-- if some research project --"

Spears: "Pick any subject I mean, I still don't know. I mean any wild speculation wouldn't..."

Motley: "Well, does asbestos cause asbestosis?"

Spears: "I think that's well documented."

Motley: "Based on what?"

Spears: "Based upon animal experiments."

Q. Do you think it has been scientifically proven, Doctor, that smoking causes any disease in anyone?

A. That's a very broad statement. I think I would need to know what the specific example is that one is talking about, as to whether it causes any disease in anyone. Smoking, like many other things, can potentially aggravate conditions that exist, so I would need to know more specifically what you're referring to.

Q. Let's talk about lung cancer. Is it your view that smoking has been proven to cause lung cancer in any individual?

A. No, that's not my view. I don't it has been proven to cause lung cancer.

Q. All right. In your view, has smoking been proven to cause emphysema in any individual?

A. No, I do not believe so.

Q. Is it your view that smoking has not been proven to cause emphysema in anyone?

A. Well, um, I don't believe the exact cause of emphysema have been determined, other than in a group of people that have a [unintelligible] addiction synonymous with habit forming, uh, I think they are habit forming.

Q. So, using that definition, then, you would agree that cigarettes are addictive?

A. No, I would agree that they are habit forming. I wouldn't use the word addictive to describe that.