Document X8zzeEOEb31QKVy8198oK91kx

FILE NAME Cape Asbestos CAPE DATE 2023 DOC CAPE189 DOCUMENT DESCRIPTION Lawyer emails Re Altrad Investment Authority and Alrad UK in default Legal - Tibbs Case Exhibit 87 Archived Thursday October 12 2023 9:35:33 AM From Carroll Todd ELCTRONIAY Mail received time Sun 20 Aug 2023 20:38:27 Sent Sun 20 Aug 2023 20:38:03 To John T. Lay Cc Lindsay Joyner Subject RE 40-01759 CAPE PLC individually and as successor in interest to CAPE ASBESTOS COMPANY FILED LIMITED by and through its duly appointed Receiver Peter D. Protopapas v ANGLO AMERICAN CROP NUTRIENTS USA LLC et al IMANMAIN.FID1086139 Importance Normal 2023 Sensitivity None Oct 18 1:13 Warning This email originated outside the GWB email system PM - I can talk now but we have dinner with kids at a neighbors house at 5:30 this evening RICHLAND From John T. Lay jlay@gwblawfirm.com Sent Sunday August 20 2023 3:38 PM - To Carroll Todd Todd.Carroll@wbd-us.com COM ON Cc Lindsay Joyner ljoyner@gwblawfirm.com Subject Re 40-01759 CAPE PLC individually and as successor in interest to CAPE ASBESTOS COMPANY LIMITED by and through its duly appointed Receiver Peter D. Protopapas v ANGLO AMERICAN CROP NUTRIENTS USA LLC et al GWBZ COMMON IMANMAIN.FID1086139 PLEAS - 5:30 Sent from my iPhone 203CP41759 On Aug 19 2023 at 5:10 PM Carroll Todd Todd.Carroll@wbd-us.com wrote EY 203CP401759 Warning - This email originated outside the GWB email system Great thank you I'm around tomorrow after church so please just give me a shout whenever it's convenient Have a good evening Todd From John T. Lay ilay@gwblawfirm.com Sent Saturday August 19 2023 10:54:46 AM To Carroll Todd Todd.Carroll Cc Lindsay Joyner ljoyner@gwblawfirm.com Subject Re 40-01759 CAPE PLC individually and as successor in interest to CAPE ASBESTOS COMPANY LIMITED by and through its duly appointed Receiver Peter D. Protopapas v ANGLO AMERICAN CROP NUTRIENTS USA LLC et al FID1086139 Let's talk tomorrow afternoon Does that work Confirmed on the extension for Mr Altrad and AIA Thanks John T Sent from my iPhone On Aug 19 2023 at 8:41 AM Carroll Todd Todd.Carroll wrote ELCTRONIAY P Warning - This email originated outside the GWB email system FILED - Lindsay John T 2023 I understand from talking to John T yesterday that your client thinks that Altrad UK is in default my Oct folks disagree and we would discuss further next week In the meantime I'm trying to get our 18 internal docketing straight for our other two clients in this case If you could please confirm that the 1:13 new deadline for Mr. Altrad and AIA to respond to the party complaint is September 1st I will PM mark that down in our system Thanks very much a great weekend and safe travels back from - Colorado T RICHLAND Todd From Carroll Todd Todd.Carroll@wbd-us.com - Sent Friday August 18 2023 4:32:53 PM COM ON To Lindsay Joyner ljoyner@gwblawfirm.com Cc John T. Lay jlay@gwblawfirm.com Subject Re 40-01759 CAPE PLC individually and as successor in interest to CAPE ASBESTOS COMPANY LIMITED by and through its duly appointed Receiver Peter D. Protopapas v ANGLO AMERICAN CROP NUTRIENTS USA LLC et al IMAN MAIN.FID1086139 PLEAS - Thanks Lindsay We represent Mr. Altrad Altrad Investment Authority and Altrad UK As I understood from our clients the earliest any of them had to respond to the party complaint 203CP41759 was next Monday so would be great if we can get an extension and have all three due to file their responses on September 1. If you could confirm by response email I would appreciate it Best Todd 203CP401759 Todd Carroll Partner Womble Bond Dickinson US LLP d 803-454-7730 m 803-446-2883 e Todd.Carroll@wbd-us.com 1221 Main Street Suite 1600 Columbia SC 29201 womblebonddickinson.com womblebonddickinson.com ? ? This email is sent for and on Wom ofbWol mbe le Bond Dickinson US LLP Womble Bond Dickinson US LLP is a member of Womble Bond Dickinson International Limited which consists of independent and autonomous law firms providing services the US the UK and elsewhere around the world Each Womble Bond Dickinson entity is a separate legal entity and is not responsible for the acts or omissions of nor can bind or obligate another Womble Bond Dickinson entity Womble Bond Dickinson International Limited does not practice law Please see www.womblebonddickinson.com/us/legal-notice forfurther details ELCTRONIAY From Lindsay Joyner ljoyner@gwblawfirm.com Sent Friday August 18 2023 4:16:06 PM To Carroll Todd Todd.Carroll@wbd-us.com Cc John T. Lay jlay@gwblawfirm.com FILED Subject 40-01759 CAPE PLC individually and as successor in interest to CAPE ASBESTOS COMPANY LIMITED by and through its duly appointed Receiver Peter D. Protopapas v ANGLO - AMERICAN CROP NUTRIENTS USA LLC et al MAIN.FID1086139 2023 Oct Todd 18 Hope you'ryou'ere doing well John T. mentioned that you called regarding an extension to align the 1:13 Third Defendants you have been retained to represent Who are those Third PM Defendants again And as John T. mentioned on the call we are happy to provide an extension - until September 1 for the Third Defendants as long as they are not currently in default To the RICHLAND extent you'd like to discuss further please let me know a good number to reach you on or feel free to call my direct dial below - Thanks COMON Lindsay Lindsay Anne Joyner Partner PLEAS ljoyner@gwblawfirm.com Gallivan White & Boyd P.A. - 40 Calhoun Street | Suite 315 | Charleston SC 29401 image001.jpg 843 414 8107 Direct | 843 735 7600 Main | 843 414 8070 Fax Mailing Post Office Box 7368 | Charleston SC 29413 203CP41759 vCard | BioURL | Website This message is from the law firm Gallivan White & Boyd PA and may be a confidential and privileged legal communication to the named recipient If you receive this message in error or are not the named recipient please notify the sender and delete this email Thank you 203CP401759