Material in this file consists of copies of legal court documents in High Court case of "The Attorney General at the relation of FX Martin, plaintiff and the Right Honourable the Lord Mayor, Aldermen and Burgesses of Dublin and the Commissioners of Public works in Ireland, Defendants" including signed affidavits and exhibits from Philip Sheil, E.M. O'Beirne and Nicholas Robinson, 17/01/1980.
Save Wood Quay Campaign 1980
[Archivist's Note: photocopies of some reports and correspondence are duplicated across this subsubsubseries as they were being used for research purposes, as part of briefs for counsel and/or as exhibits in court.]
Photocopies of correspondence 22/11/1969-09/03/1979, several books of pleadings covers and indices with some notation, a Parliament Barristers notebook marked "NK Robinson Wood Quay 2" with handwritten notes and other loose documents [duplicates of documents from the book of pleadings/book of appeal?]. Material also includes press release from Friends of Medieval Dublin 30/01/1978.
Photocopies with notation and duplicates of legal documents most likely for use in appeal including notice of motion and court order 28/11/1977; typed list of experts and statement signed by most of them recommending every possible effort be made for fullest scientific archaeological excavation of what remains on site, 08/05/1978; motion for interlocutory injunction 14/12/1977; Supreme Court order 25/01/1978; Extracts from minutes of the National Monuments Advisory Council and its standing committee 28/11/1977-06/02/1978; High Court order 11/07/1978; "Consent under the National Monuments Act", legal document issued by Commissioners of Public Works and Dublin Corporation 02/08/1978; affidavit of FX Martin 100/1/1979; affidavit of Philip Sheil (solicitor of William Dundon), of Charles Harry Clifton, representative of Donal Keogan Associates Consulting engineers, of George Hegarty, Principal Officer of Development Department, 12/01/1979 and of Joseph Raftery, Director of National Museum of Ireland, 19/01/1979; typed document (photocopy) listing instances "of bulldozing and removal of archaeological deposits without archaeological supervision since consent of 29th August 1978"; court order High Court 01/02/1979; typed photocopies of judgement delivered 07/03/1979 by Chief Justice O'Higgins, Supreme Court, one of which was annotated; Supreme Court order 07/03/1979; photocopy of typed statement by FX Martin re taking next step and applying to European Commission of Human Rights, 11/03/1979.
Copy of Book of Appeal "1979 No 133P The Supreme Court The Attorney General at the relation of Francis X Martin plaintiff, and The Right Honourable the Lord Mayor Aldermen and Burgesses of Dublin and the Commissioners of Public Works in Ireland, Defendants" Book 1, Book 2A, Book 2B; Book of Appeal (not copy) Book 3.
Brief for Counsel (DB, SC, T.C. Smyth, SC & MR B.L.) and background material on case including drafts and photocopies of court documents such as affidavits, plenary summons, notices of motion, exhibits referred to in affidavits, and other contents of book of pleadings along with notes from Mary Robinson. Material includes typed opinion of Counsel Donal Barrington 23,30/01/1979; index of book of pleadings; affidavit of Professor Reginald W Kirwan, 09/01/1979 with notation; photocopy of typed names and addresses of standing committee of National Monuments Advisory Council; photocopies of typed defence of defendants and replies to defence which were delivered by Nicholas Robinson, 14-20/2/1979; notice of appeal, 21/02/1979; photocopy of typed letter from Principal Officer to Dr AT Lucas, Director of NMI 16/05/1973; photocopies of correspondence between NR & Co and Louis Dockery, Chief State Solicitor 09/01-22/02/1979, Dr George Eogan, Chairman National Monuments Advisory Council 23-25/01/1979, Philip Sheil and William Dundon, Law Department, Dublin Corporation 23/01-28/02/1979, Dr Peter McCabe, McCabe Delaney & Associates 01/02/1979; poster (black type on yellow background) for organ music and bell ringing event, Christ Church Cathedral, 16/02/1979, issued by Friends of Medieval Dublin including view of Cathedral taken from across Wood Quay, which would disappear once civic offices built.
Folder labelled "Brief for Counsel (6) Documents Discovered from 1st Defendants [NB + duplication]" including correspondence 1974-1976 between Dublin Corporation and the National Museum of Ireland (NMI) under director AT Lucas, photocopies of reports for the Lord Mayor, Aldermen and members of Dublin City Council 1951-1975, photocopy of letter from David Greene, President of the Royal Irish Academy to M Macken, City Manager asking for full investigation into Civic Offices site 09/1974 and photocopy of typed minutes of meeting between NMI and Architects re Archaeological implications of Civic Offices project, 13/05/1974; report "Exploratory Study of the Tourism Potential of Wood Quay", Colin McIver Associates Ltd, Dec 1977; folder labelled "AG (FX Martin) v Dublin Cor[?] 1979 Precedents for 1979 injunction.
Folder labelled "Correspondence & Misc A.G. (F.X. Martin) v Dublin Corporation 1979 No 133P Wood Quay Injunction”. Includes correspondence, copies of correspondence, handwritten notes, maps and handwritten note and typed version on the state of play on injunction proceedings; correspondence between Louis Dockery, Chief State Solicitor on behalf of the Attorney General and Nicholas Robinson (NR), 09-31/01/1979; several draft general endorsement of claim documents; letter from George Eogan, National Monuments Advisory Council to NR nominating archaeological experts to participate with clients' two engineering consultants in order to assess archaeological consequence of any proposed solution relating to the safety of the site, 25/01/1979; photocopy of map of agreement with National Museum of Ireland (NMI), Stephenson Gibney Design Associates and Dublin Corporation, with notation; copies of press statements by the Commissioners of Public Works on the Wood Quay reprieves August and Oct 1978, with cover note from Olivia O'Leary, handwritten notes of Mary Robinson on case, and to-do lists; newspaper cuttings; photocopies of letters from the professional archaeological assistants working in the excavation under Patrick Wallace, to the Minister for Education, and Minister for Environment, along with newspapers, in relation to actions taken by them to prevent further mechanical excavations (Jan 1979); map of Wood Quay Fishamble Street site and excavation work marked in colour pencil; notes re affidavit of George Eogan; correspondence between Eogan and NR in relation to the Joint Consent of 29/08/78 (15-17/01/1979); photocopy of typed letter from Joseph Raftery, Director, NMI and Director of National Parks and Monuments Branch OPW, 29/11/1978 with notation; summons to attend High Court for Patrick Wallace and Peter Danaher, 23/01/1979; photocopy of report of Dr Eogan and Dr Michael Herity and Peter Danaher following site visit 26 Jan 1979; photocopies of letters from NR to various parties requesting attendance at the hearing 01/02/1979; copy of affidavit of Peter McCabe 27/01/1979; notes typed on affidavit of George Eogan; copies of letters from NR to defendants informing them that NR and Co have received Fiat of the AG to issue proceedings at the relation of FX Martin to restrain any or further mechanical excavations and that counsel was applying to Judge of High Court for an injunction the following day (10/01/1979); copies of cover letter from NR & Co sent to Office of AG re enclosed plenary summons for file 10/01/1979 and to Philip Sheil, c/o William Dundon Law Agent, Dublin Corporation in relation to enclosed affidavits, 10/01/1979; batch of correspondence with commissioners and Law Agent relating to authority for the excavations 27/11/1977-08/06/1978.
Book of Pleadings 1979 No. 133P The High Court, between the Attorney General at the relation of Francis X Martin, and The Right Honourable the Lord Mayor Aldermen and Burgesses of Dublin, Stephenson and Associates and John Paul and Company Limited, and some loose pages which are copies of sections of the book of pleadings; typed copy of Judge Gannon's judgement 12/02/1979, and typed transcript of some of the hearing; Parliament Barristers Note Book labelled "Wood Quay III" with handwritten notes (Mary Robinson's).
Material in this file consists of photocopies of various affidavits and legal documents which were possibly to form part of book of pleadings for later trial dates, or were for use by legal counsel, along with research material and notes on progress of trial. It includes copy of circular from Dr Anngret Simms, secretary of Friends of Medieval Dublin, seeking contributions from readers to legal fund; typed photocopy of National Monuments Advisory Council (NMAC) standing orders; notes on points to raise with counsel, typed document giving state of play on injunction proceedings; photocopy of signed report from Dr George Eogan, Dr Michael Herity and Mr Peter Danaher following their visit to the Wood Quay site (28/01/1979); photocopy of letter from FX Martin (FXM) to JB Molloy, City Hall, 08/01/1978 re instituting proceedings for an application for an injunction in the High Court, which was signed and submitted as Exhibit A referred to in FXM's affidavit dated 10/01/1979; photocopies of typed affidavits from Michael Pascal Scanlon (19/01/1979), George Hegarty (15/01/1979), Peter McCabe (27/01/1979), George Eogan (29/01/1979), Nicholas Robinson (29/01/1979) ; notice of Cross examination of deponents, signed Nicholas Robinson & Co (22/01/1979); type counsel's opinion of Donal Barrington, Senior Counsel, 23/01/1979 and 29/01/1979; photocopy of typed letter from Nicholas Robinson & Co to Eogan 23/01/1978 which was signed and submitted as Exhibit G referred to in Eogan's affidavit dated 29/01/1979; photocopy of typed NMAC standing orders which was signed and submitted as Exhibit H referred to in Eogan's affidavit dated 29/01/1979; photocopies of typed document from FXM undertaking to defray the Attorney General's costs and expenses as co-relator in any proceedings 01/1979; photocopy of typed list of NMAC members which was signed and submitted as Exhibit A referred to in Liam de Paor's affidavit dated 15/01/1979; draft and photocopies of plenary summons to plaintiffs; photocopies of general endorsements of claim.