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T here are a few reasons why 20 became the standard: Historical preceden t: Early mass-produced cigarettes were packaged in counts of 20 for convenience and pricing consistency

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That unduly narrowed the issue for the jury to consider. The court also ruled that though plaintiffs counsel while objecting to the proposed instruction at the charge conference did not specifically object to the instruction post-charge as contemplated by Rule 51(b) of the Massachusetts Rules of Civil Procedure, the judges acknowledgement pre-charge that both parties have lodged their objections with regard to the jury instructions as read was sufficient to preserve the issue for appeal