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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

• 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

• 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

• boxlist of 79 boxes of NAAC documentation plus more detailed inventory (several versions)
• covering letter from Steven Kazan / Daniel D Murphy to James Walker, 2 June 1987, re general summaries and lists of NAAC documents and NAAC sales documents (the latter from 47 reels of microfilm)
• "Mau exhibit list", presumably relating to suit Geneva Eileen Mau (widow of William R Mau)
• "North American Documents Index", 10 March 1994, listing all documents x4: by ‘from’, ‘to’, ‘what’, ‘subject’

• 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.

Depositions from asbestos lawsuits 1975-1983 filed in Texas, Illinois, Pennsylvania and New Jersey.

• deposition of Charles G Morgan (20 May 1975), in Herman Yandle et al. v. PPG Industries Inc. et al., District Court of Eastern Texas
• deposition of Charles G Morgan (27 May 1975), in William J Johnson et al. v. NAAC, Tenth Circuit Court of Illinois, Peoria County
• deposition of Charles G Morgan (31 October 1980), in Anthony A Barber et al. v. Pittsburgh Corning Corporation et al., Court of Common Pleas of Allegheny County, Pennsylvania, Civil Division
• deposition of Charles G Morgan (20 February 1981), in James R Daisy et al. v. Johns Manville Sales Corporation et al., District Court for the District of New Jersey

Morgan was the former president of the North American Asbestos Corporations (NAAC).

• deposition of John George Richardson (20 April 1983), in Lois J Thacker et al. v. UNR Industries Inc., Circuit Court of the Eleventh Judicial Circuit, County of McLean, Illinois
• deposition of John Neill Clarke (21April 1983), in Lois J Thacker et al. v. UNR Industries et al., Circuit Court of the Eleventh Judicial Circuit, County of McLean, Illinois

Originally included also a duplicate of deposition Geoffrey Arthur Higham (4 June 1975), in Herman Yandle et al. v. PPG Industries, Inc. et al.; see FLYNN/1/2/1.

John George Richardson held a number of corporate directorships before becoming a director at Charter Consolidated Services c.1971.
J Neill Clarke was partner in a firm of chartered accountants during the 1960s and joined Charter Consolidated Services c.1969.

• 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.

• 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.

During his period as an industrial journalist for the 'Socialist Worker', 1972-1978, Flynn worked closely with activists from the Glasgow branch of the Transport and General Workers Union and with Tom Woolf and John Pickering, both of them W H Thomson solicitors covering lawsuits against Central Asbestos in Bermondsey, London, and Acre Mill in Hebden Bridge, West Yorkshire (the latter not much documented here).

In reverse chronological order:

• copy of email, informing Geoffrey Tweedale of John Todd's death in 2004. In the 1970s, Todd had been a prominent representative of the Glasgow branch of the Transport and General Workers Union
• papers and correspondence 1974-1978. Includes copies of correspondence between Todd and the Health & Safety Executive, as well as of the certificate for the asbestosis-related death of Angus Cairns, insulating engineer, November 1975
• copy of Flynn's ‘Asbestos murders’ (1974), a series of articles in The Socialist Worker indicting the Scottish lagging industry
• copy of the pamphlet version of 'Asbestos murders’, published as ‘Asbestos: the dust that kills in the name of profit’ (London, 1974)
• Flynn's background research for 'Asbestos murders': lists of "certified dead from asbestosis" and "certified receiving pension"; transcripts of Flynn's conversations with Glasgow laggers and their union representatives; some correspondence, typescript notes of a meeting with laggers Arthur Rhodie, Jim Gegathy and John Todd, 14 November 1973
• papers including press coverage 1967-1974

Bermondsey based factory Central Asbestos Company Ltd was sued by 7 former workers who had contracted asbestosis. In July 1970, the High Court found in favour of the plaintiffs, concluding that Central Asbestos had breached the Asbestos Industry Regulations of 1931. Damages awarded totalled £86,469. Flynn covered the trial and subsequently followed up the matter, including with HM Inspectorate.

The 7 plaintiffs were Robert Frederick Smith, Francis John McCourt, Ronald Francis Drake, Walter Dodd, Donald Derrick Roof, Edward Edwin Raper and James Sampson.

Includes:

• Flynn's notebook on the trial, Smith et al. v. Central Asbestos Company Ltd
• Flynn's correspondence with Brian Harvey, HM Chief Inspector of Factories; also his notes of an interview with retired factories inspector Miss Alice Crossthwaite
• press coverage 1970-1974
• photocopies of HM Inspectorate correspondence 1953-1967
• copy of Lord's opinions on the appeal of Central Asbestos Company Ltd v. Dodd, June 1972 (appeal dismissed by 3:2)
• notes of evidence taken at the inquest of another former Central Asbestos worker, Frederick Robert Gibbins, 1972, and photocopy of medical file Edward Edwin Raper
• photocopy of judgement Smith et al. v. Central Asbestos Company Ltd

Correspondence and papers, Flynn's drafts and manuscript notes c.1970-mid-1980s. Includes:

• draft article on the background of George VI's lung cancer
• draft article for Socialist Worker c.1978, on the findings of the Advisory Committee on Asbestos (Simpson Committee), whose final report appeared in October 1979
• correspondence re Dr S Roodhouse Goyne, author of the first report on asbestosis ever in the UK
• Flynn's notes on the Asbestos Industry Regulations of 1931
• Flynn's notes on asbestos and railway workers
• list of key experts on asbestosis and related disease

Correspondence and press reports re the continuing threat posed by asbestos around the globe. Contains:

• draft presentation (typescript with Flynn's manuscript annotations) on South Africa's mining industry, possibly given at the Joint Hazards Campaign / TUC Asbestos Conference 'Asbestos still kills', April 2001, London
• correspondence including with international solicitors, expert witnesses (among them Barry I Castleman) and asbestos ban campaigners, re the plight of asbestos victims, the impact of the liquidation of assets of Chester Street Insurance Holdings Ltd, etc. Also includes correspondence re expert witness Richard Doll, author of 'Mortality from lung cancer in asbestos workers' (1955), and re plans for Doll's personal archive
• press cuttings re asbestos compensation litigation, the legacy of asbestos in the UK and South Africa, Geoffrey Tweedale's new book (with Richard Hansen), 'Magic mineral to killer dust: Turner & Newall and the asbestos hazard' (2000), medical provisions in South Africa