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Smith v Phillip Morris Companies Inc. & Ors [2006] EWHC 916 (QB) (27 April 2006) (

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Evidence (proceedings in Other Jurisdictions) Act 1975. An order under the Evidence (Proceedings in Other Jurisdictions) Act 1975 for oral examination of a non-party to proceedings in the United States of America was set aside where the letter of request seeking the order was couched in such wide terms that it amounted to an impermissible investigation and the letter of request could not properly be modified or made subject to conditions.

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