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• Plaintiff’s memorandum of law (in re asbestos personal injury cases, Arrington Lead No 93-9-114 et al.) in opposition to Charter’s motion to dismiss the second amended complaint for lack of personal jurisdiction, submitted by Hayden S Dent, 6 December 1995, in the Circuit Court of Jones County, Mississippi, Second Judicial District

Argues among other things that at all times Charter and its predecessor Central Mining controlled Cape's mining operations in South Africa and that therefore the corporate distinction between the two companies should be disregarded and Charter should assume Cape's contacts with the State of Mississippi. Further, that the Court should disregard the corporate veil between Cape and Charter because Cape had introduced into the marketplace a product which it knew would be dangeous to the end user. Etc.

• coroner's report on Edwin W Holland, d. 2 April 1985 (plaintiff’s exhibit)

NAAC correspondence, as follows:

• 1974-1976 (chiefly between Joan Holtze, NAAC, and J L Sparks, Group Financial Controller of Cape Industries Ltd, London)
• 1969-1973 (chiefly from and to Charles G Morgan / Joan Holtze (both NAAC) and representatives of Cape Asbestos in the UK, South Africa and subsidiaries elsewhere)
• 1962-1968: correspondence of Robert E Cryor including minutes of shareholder meetings and meetings of company directors

• Cape/subsidiaries correspondence 1964-1972. Source uncertain (no exhibit marks, no covering correspondence)
• instructions from J L Sparks, Group Financial Controller Cape Industries Limited, to Financial Directors/Company Secretaries – all subsidiaries, 1974-1978

• deposition of Dr Ian Webster (12 November 1996), in Asbestos Personal Injury Cases, Arrington Lead, Civil Action No 93-9-114, Circuit Court of Jones County, Mississippi. Deposition taken in Johannesburg, South Africa. Webster was senior pathologist at the National Centre for Occupational Health, Johannesburg, South Africa

• deposition of Anthony Mendelle (13 November 1984), in Darlene Smith v. Pittsburgh Corning Corp, PPG Industries Inc., Cape Industries Ltd, Cape Asbestos Fibers Ltd, Cape Boards & Panels Ltd etc., Court of Common Pleas, Allegheny, Pennsylvania. Mendelle was products manager (1956-1960) and production manager (1960-1968) at Cape Asbestos Company Ltd, Barking, UK

• deposition of Malcom George King (24 September 1979), in [unidentified court case], UK. King had been employed by CSR Ltd, Sydney, a building products company in Australia and New Zealand, since 1933

Includes covering correspondence from Robert Blackwell (research assistant to Hayden S Dent, attorney), 20 May 1997

Set of exhibits, marked and annotated. Includes:

• civil subpoena of Max E Meyer in Delora Stewart et al. / Geneva Eileen Mau et al., both v. NAAC, 1987
• reponse to request to admit in Delora Stewart et al. v. NAAC (8 January 1987), Circuit Court of the Eleventh Circuit, McLean County, Illinois
• answers to interrogatories in Dorothy Betts et al. v. Unarco Industries et al. (1985), Circuit Court of the Eleventh Circuit, McLean County, Illinois
• Cape Asbestos correspondence 1954-1985, including between Richard Gaze (the company's chief scientist), company solicitors, additional legal support (Davis, Arnold & Cooper Solicitors, London; Lord Bissell & Brook, Chicago). See also Gaze deposition at FLYNN/2/3/3

Flynn's listing of his personal papers on Cape Industries.

• deposition of Joan Holtze (12 April 1979 ), in Geraldine Ellenburg v. NAAC et al., Circuit Court of the Eleventh Judicial Circuit, County of McLean, Illinois
• deposition William S Haines (8 May 1980), in Charlotte Hammond vs Cape Industries & NAAC; and Delora Stewart v. EGNEP et al., Circuit Court of McLean County, Illinois, General Division
• deposition of Max E Meyer (24 March 1981), in Anthony A Barber et al. v. Pittsburgh Corning et al., Court of Common Pleas of Allegheny County, Pennsylvania

Joan Holtze was the secretary and assistant treasurer at the North American Asbestos Corporation.
William S Haines was a former chairman of Safety & Claims Services Inc., which did work for Union Asbestos & Rubber Company.
Max E Meyer was a lawyer employed by Lord, Bissell & Brook, who represented Cape Asbestos.

Shows Harts Lane area, Barking.

• correspondence between Stephen A Milwid and Richard Gaze re Pittsburgh Corning litigation, 1977 (part of an exhibit, 1986). See further correspondence at FLYNN/2/2/5
• deposition of Richard Gaze (4 + 5 June 1975), in Herman Yandle et al. v. PPG Industries, Inc. et al., District Court, Eastern District of Texas, Texas
• deposition of Francis Howard (19 April 1983), in Lois Thacker et al. v. UNR Industries, Inc. et al., Circuit Court of the Eleventh Judicial Circuit, County of McLean, Illinois

Richard Gaze was the executive director of Cape Industries.
Francis Howard was an accountant. Among others he worked for Anglo American Corporation of South Africa (North America) Ltd, 1968-1970, and for Charter Consolidated Services from 1975.

• press clippings 1977-1983
• photocopies of North American Asbestos Corporation (NAAC) correspondence and papers 1953-1983, including solicitors correspondence
• (marked) copy of memorandum by Richard K Decker, November 1962, advising on legal interpretation of the relationship between Cape and its subsidiary NAAC viz. whether US courts would be inclined to think they have jurisdiction of Cape, (a) because Cape's effect on US trade could be shown to be direct and substantial, and (b) because the NAAC as Cape's agent plays an active part in Cape's business which "is continuous and could not be easily carried out without NAAC"

Originally contained a (duplicate) copy of the deposition of William S Haines (June 1980), in Charlotte Hammond v. Cape Industries & NAAC, etc. See FLYNN/2/3/4

Photocopies of 'Cape Asbestos Company Magazine' (the house journal of Cape Asbestos Company Ltd), December 1951 to Autumn 1963.

Contains occasional post-it markers by either Flynn or Tweedale.

Correspondence chiefly with personal injury lawyer Richard Meeran of Leigh Day & Co solicitors, 1994-2001. Relates to case Afrika et al. v. Cape plc and its argument that a parent company owes a direct duty of care in tort to anybody injured by a subsidiary company in a group. Includes:

• press coverage 2004-2005
• joint asbestos initiative paper of the International Miners Organisation, African Miners Federation, National Union of Mineworkers, and Leigh Day & Co solicitors
• copy of opinions of the Lords of Appeal for Judgement in the cause of Schalk Willem Burger Lubbe et al. v. Cape plc (2000)
• copy of judgement Rachel Jacoba Lubbe & Ors v. Cape plc (1999)
• Flynn's notes on a meeting on foreign plaintiffs and access to English courts in transnational litigation, British Institute of International and Comparative Law and Solicitors' Human Rights Group, November 1999
• copy of judgement Moses Fano Sithole et al. v. Thor Chemical Holdings Ltd et al. (1998)
• copy of draft judgement Rachel Jacoba Lubbe & Ors v. Cape plc (1998)
• copy of judgement Rachel Jacoba Lubbe et al. v. Cape plc (1997)
• copy of opinions of the Lords of Appeal for Judgement in the cause of Connelly v. RTZ Corporation plc et al. (1997)
• copy of affidavit John Carol Anthony Davies in Rachel Jacoba Lubbe et al. v. Cape plc (1997)
• copy of affidavit Richard Meeran in Rachel Jacoba Lubbe et al. v. Cape plc (1997)
• copy of consolidated statement of claim, Busisiwe Ngcobo et al. v. Thor Chemicals Holdings Ltd et al. (1995)
• copy of judgement Edward Connelly v. RTZ Corporation plc (1996)

• set of court papers in the matter of Charlotte Hammond v. Circuit Court of Cook Country et al. (1981), Supreme Court of the State of Illinois; & Charlotte Hammond v. Cape Industries Limited & NAAC (1981), Circuit Court of the Eleventh Judicial Circuit, County of McLean, Illinois
• photocopies of medical death certificates issued in Illinois 1978-1981
• photocopies c.1979 of papers from James Bennett's claim against the Union Asbestos & Rubber Company (Unarco) of Chicago, 1940
• photocopies of correspondence between Unarco and its insurers over occupational disease, 1952-1958
• short publication on asbestos heir Tommy Manville, 1940

Annotated copies (photocopies and/or originals) of Cape Industries / Cape plc annual reports and accounts 1974-2000, incomplete set (1984, 1997 and 1999 missing).

1976-1986: includes also reviews.

There also is an original Charter Consolidated annual report 1981.