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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

• 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

Communications and documentation obtained chiefly through contacts with American litigators whose clients included victims of asbestos-related disease. First among these litigators was James Walker of Walker & Wylder, Bloomington, Illinois, whose correspondence and document exchange with Flynn started c.1982.

Cape's North American subsidiaries included:

• North American Asbestos Corporation (NAAC)
• Union Asbestos & Rubber Company (Unarco)
• PPG Industries Inc.