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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.

• press coverage 2003-2005 including 'Bloomington woman awarded $5 million in wrongful death asbestos suit', 2005
• Flynn's notes on NAAC/Cape, sample of NAAC corporate seal.

Remaining content exactly duplicated material listed at GB 249 FLYNN/2/2/8 and has therefore been removed.

• 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

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)

Correspondence and news coverage following the out of court settlement in the South African group action brought against Cape plc (formerly Cape Asbestos Company Ltd, from 1974 Cape Industries Ltd) in December 2001, after a 5 year battle. Also earlier notes, correspondence and research materials on the South African asbestos industry. Includes:

• correspondence with ITV re a film project 'You will know us by the trail of death' (originally outlined in 1988 under the title 'Outrageous misconduct - asbestos as metaphor'; see FLYNN/2/1/3)
• set of microfiches of Charter Consolidated company papers, filmed 1978
• Flynn's handwritten notes on his background research c.1980-1982, including on the suppression of the research of the Johannesburg Pneumoconiosis Research Unit
• correspondence between Richard Creasey (BBC, formerly World in Action) and Anthony Mendelle (employee at Cape Asbestos Company Ltd, Barking 1956-1968) following the BBC documentary 'The right to know', April 1974, re producing a WIA documentary about Cape Asbestos in South Africa. See also Mendelle deposition (1984) at FLYNN/1/2/6. Creasey had conducted the investigation for WIA documentary 'The dust at Acre Mill' (transmitted in June 1971), the first programme to bring the lethal dangers of asbestos to the attention of the general public, on the example of the Acre Mill asbestos factory at Hebden Bridge, Yorkshire.

• 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

• 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

Shows Harts Lane area, Barking.

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.

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

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.

Microfiches of company registration documents.

Also photocopies of the following:

• successive versions of Memorandum and Articles of Association, Cape Asbestos Company Ltd / Cape Industries Ltd
• Memorandum and Articles of Association, Cape Industries Overseas Ltd
• particulars of Directors and Secretaries, notifications of changes
• certificates of incorporation
• diverse company registration papers 1975-1980
• Register of Mortgages and Charges, etc. Company Search Report 1996

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