Affidavit of Robert Proctor
AFFIDAVIT OF DR. ROBERT PROCTOR IN SUPPORT OF PLAINTIFFS' MOTION FOR PROTECTIVE ORDER STATE OF FLORIDA COUNTY OF VOLUSIA Before me this day personally appeared Dr. Robert Proctor, who, being first duly sworn, deposes and says: 1. I am over the age of twenty-one. 2. The statements contained herein are based upon my personal knowledge. 3. I am a resident of California and a Professor of History at Stanford University. 4. One of my principal research specialties is the history of the tobacco industry. 5. Forty university professors of history have testified as paid expert witnesses for the defense in tobacco litigation, rendering them unwilling to publicly criticize the tobacco industry. 6. Only two university professors of history regularly testify against the tobacco industry in Court, and I am one of these two. 7. One of my specialties is the history of the tobacco litigation, including issues such as when the companies became aware of the lung cancer hazard and the addictive properties of cigarettes, and what steps they undertook to cover up that knowledge. 8. As a consequence of my specialty, and my willingness to testify, the tobacco industry has spent years trying to harass, intimidate, and use multiple legal means to prevent me from testifying in litigation. 9. I am currently in the process of writing a book, which is tentatively entitled Golden Holocaust: A History of Global Tobacco. This book is critical of the tobacco industry and will contain previously unpublished information regarding tobacco industry practices 10. This work is unfinished, and has not been through the normal process of editing, peer-review, cite-or-spell check, or shown to a publisher. Furthermore, this draft currently contains my outlines, mental impressions, and notes. 11. The complete draft of the Manuscript has not been exhibited to any person. Certain individuals have assisted me by reviewing and commenting on portions of the Manuscript. 12. Release of the unpublished Manuscript could cause damage to my professional credibility and professional standing as this Manuscript is a work in progress and does not represent completed and fact-checked research. FURTHER AFFIANT SAYETH NOT. _______________________________ DR. ROBERT PROCTOR STATE OF CALIFORNIA COUNTY OF ________________ |