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King & Spalding King & Spalding LLP 1185 Avenue of the Americas KING & SPALDING New York, NY I 0036-4003 Tel: (212) 556-2100 Fax: (212) 556-2222 www.kslaw.com Edward G. Kehoe Direct: (212) 556-2246 E-mail: [email protected] June 21,2013 VIA ELECTRONIC MAIL Jonathan C. Hamilton White & Case LLP 701 Thirteenth Street, NW Washington, DC 20005 Re: Renco v. The Republic o(Peru Dear Jonathan: Enclosed please find a copy of a new complaint filed by ninety nine Peruvian citizens in the court in St. Louis Missouri. The filing of this action brings the number of total pending cases to twenty, and the total number of plaintiffs to 803. Counsel for the defendants plan to remove this case to federal court, as they have with the previously-filed cases. Renco and its affiliates reiterate the requests for action by Centromin, Activos Mineros S.A.C, and the Republic of Peru as outlined in my prior correspondence, including in my letter to you dated November 16, 2012. Sincerely, - 5~ Edward G. Kehoe Enclosures 2Ill0475 F'!Lf.U i JUDICIAL CF{i 1 } T CL Ef\ ~·\ '::) ri Fi~ IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATEOFMISSOURI 2013,JIJ>1--3 i='!;1 f,:i,.J SISTER KATE REID and MEGAN ) _ }JJJJl}J .. r· 1 . HEENEY as Next Friends of J.D.A.Q., ) J,F.A.Q., A.B.A.V., J.F.A.V., D.BY., E,M.CH., ) E.G.CH., H.H.C.H., M.M.CH., M.C.P., ) J.D.D.C., J.J.D.C., R.D.C., V.L.D.C., J.M.D.C., ) lL.D.C., K.J.D.C., N.J.D.C., R.A.D.C., ) S.D.D.C, T.E.D.C., J.C.F.L., F.P.G.V., I.J.G.V., ) J.I.G.V., S.S.G.V., N.G.C., S.G.C., S.I.G.C., ) K.E.G.S., A.E.G.Y., D.E.G.Y., E.E.G.Y., ) J.J.G.H., J.L.G.H., P.R.G.H., J.D.H.M., P.E.H.M., D.N.H.C., M.J.H.C., M.S.H.C., ) W.X.H.C., A.A.L.V., J.J.L.V., K.E.L.V., ) A.N.M.C., J.F.M.M., D.L.M.M., L.E.M.M., ) M.A.M.M., C.L.O.F., H.A.O.F., L.O.O.F., ) M.A.O.F., N.P.O.F., B.R.O.M., H.E.O.M., ) Case No. I?J22--CCu il-80 J.B.O.M., J.J.O.M., P.L.O.M., C.K.O.L., J.J.O.L., ) M.O.L., A.O.P.A., P.S.P.A., A.P.G., J.M.P.M., ) Division No. O.F.P.S., S.N.P.S., A.Y.Q.H., W.D.Q.H., ) D.L.R.C., 1-i.F.R.C., I.J.R.C., J.J.R.C., .J.R.C., ) JURY TRIAL DEMANDED J.J.R.C., K.A.R.C., K.R.C., R.E.R.C., S.E.R.C., ) Y.R.C., J.J.R.C., A.F.R.L., C.M.R.L., M.R.R.L., ) T.V.R.M., U.U.R.R., H.M.R.R., J.L.R.Q., .I.M.R.Q., K.T.R.Q., M..J.R.Q., J.M.R.U., ) B.L.R.C, .J.G.V.M., A.K.Y.R., L.P.V.R., and ) C.E.V.C. ) Plaintiffs, ) ) v. ) ) ) DOE RUN RESOURCES ) CORPORATION, ) a New York corporation, ) Serve: C T Corporation System ) 120 South Central A venue ) Clayton, MO 63105 ) ) and ) ) ) ) ) ) ) D.R. ACQUISITION CORP., ) a Missouri corporation, ) Serve: C T Corporation System ) 120 South Central Avenue ) Clayton, MO 63105 ) ) and ) ) MARVIN K. KAISER ) Serve: I 0 N. Kingshighway, ) Apt. 10C ) St. Louis, MO 63108 ) ) and ) ) ALBERT BRUCE NEIL ) Serve: 129 E. Clinton Place ) Apt. 2D ) Kirkwood, MO 63122 ) ) and ) ) JEFFERY L. ZELMS ) Serve: 406 N. Point Dr. ) Camdenton, MO 65020 ) ) and ) ) THEODORE P. FOX III ) Serve: 401 Equestrian Pointe Ct ) Chesterfield, MO 63005 ) ) and ) ) DANIELL. VORNBERG ) Serve: 556 Purdue Ave. ) University City, MO 63130 ) ) and ) ) ) ) 2 THE RENCO GROUP, INC. Serve: 30 Rockefeller Plaza 42nd Floor Suite 4225 New York, New York, 10112 and RENCO HOLDINGS, INC., a New York corporation, Serve: 30 Rockefeller Plaza 42nd Floor Suite 4225 New York, New York, 10112 and IRA L. RENNERT, Serve: 30 Rockefeller Plaza 11 42 d Floor Suite 4225 New York, New York, 10112 Defendants. PETITION FOR DAMAGES -PERSONAL INJURY COME NOW Plaintiffs, Sister Kate Reid and Megan Heeney as Next Friends of J.D.A.Q., J.F.A.Q., A.B.A.V., J.F.A.V., D.B.Y., E.M.C.H., E.G.C.H., H.H.C.H., M.M.C.H., M.C.P., J.D.D.C., J.J.D.C., R.D.C., V.L.D.C., J.M.D.C., J.L.D.C., K.J.D.C., N.J.D.C., R.A.D.C., S.D.D.C., T.E.D.C., J.C.F.L., F.P.G.V., J.J.G.V., J.LG.V., S.S.G.V., N.G.C., S.G.C., S.I.G.C., K.E.G.S., A.E.G.Y., D.E.G.Y., E.E.G.Y., J.J.G.H., J.L.G.H., P.R.G.H., J.D.H.M., P.E.H.M., D.N.H.C., M.J.H.C., M.S.H.C., W.X.H.C., A.A.L.V., J.J.L.V., K.E.L.V., A.N.M.C., J.F.M.M., D.L.M.M., L.E.M.M., M.A.M.M., C.L.O.F., H.A.O.F., L.O.O.F., M.A.O.F., N.P.O.F., B.R.O.M., H.E.O.M., J.B.O.M., J.J.O.M., P.L.O.M., C.K.O.L., J.J.O.L., M.O.L., A.O.P.A., P.S.P.A., A.P.G., J.M.P.M., O.F.P.S., S.N.P.S., A.Y.Q.H., W.D.Q.H., D.L.R.C., H.F.R.C., I.J.R.C., J.J.R.C., J.R.C., J.J.R.C., K.A.R.C., K.R.C., R.E.R.C., S.E.R.C., Y.R.C., J.J.R.C., A.F.R.L., C.M.R.L., M.R.R.L., T.V.R.M., G.D.R.R., H.M.R.R., J.L.R.Q., J.M.R.Q., K.T.R.Q., 3 M.J.R.Q., J.M.R.U., B.L.R.C., J.G.V.M., A.K.V.R., L.P.V.R., and C.E.V.C. hereinafter "minor plaintiffs," and for their Petition against Defendants state: 1. This is an action to seek recovery from Defendants for injuries, damages and losses suffered by each and every minor plaintiff named herein, who were minors at the time of their initial exposures and injuries as a result of exposure to the release of lead and other toxic substances from Defendants' ownership, use, management, supervision, storage, maintenance, disposal and release of materials containing lead and other toxic substances in the region of La Oroya, Peru. At critical times during gestation and/or their developmental years and to the present, the minor plaintiffs were exposed to damaging levels of lead and other toxic substances. Minor plaintiffs' damages and losses include but are not limited to physical and psychological injuries, learning and other permanent disabilities, pain, mental anguish, emotional distress, the cost of medical, educational, and rehabilitation expenses, and other expenses of training and assistance, and loss of earnings, income, and earning capacity. THE PLAINTIFFS 2. Prior to filing the Petition, the Court entered an Order appointing Sister Kate Reid and Megan Heeney as Next Friends on behalf of the minor plaintiffs listed above for the purpose of prosecuting on their behalf, claims for damages as alleged herein. 3. Plaintiff Megan Heeney is and at all times relevant herein has been a resident of the City of Saint Louis, Missouri. 4. Plaintiff Sister Kate Reid is and at all times relevant herein has been a resident of the City of University City, Missouri. 4 THE DEFENDANTS 5. Defendant The Doe Run Resources Corporation ("Doe Run") is and at all times relevant herein was a New York corporation with its principal place of business in Missouri. At all times relevant hereto, Defendant Doe Run owned, operated, used, managed, supervised, stored, maintained, and/or controlled the properties and the waste on such properties which contained and stored materials containing lead and other toxic substances released from the La Oroya metallurgical complex (hereinafter "the complex" or "Defendants' metallurgical complex"). 6. Defendant Doe Run wholly owns Doe Run Cayman, Ltd., a Cayman Island corporation, which owns Doe Run Peru. 7. Doe Run Cayman Ltd. has no operations separate from "owning" Doe Run Peru. 8. At all times relevant hereto, Defendant Doc Run owned and operated Doe Run Peru. 9. Defendant D.R. Acquisition Corp. is and at all times relevant herein was a Missouri corporation with its principal place of business in Missouri. D.R.
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