Earl Rawley does briefly mention him once to Jake:
"There's one thing about Los Angeles that makes it different than most places, John, and that's two things. You got a desert with oil under it, and, second, you got a lot of water around it. Hollis Mulwray and Noah Cross moved the water onto this desert, and we have to move people the same way they moved the water. Without my oil, you got no cars. Without cars, you got no road construction, no sidewalks, no city lights, no gas stations, no automotive service, and no Berman subdivision out in the tules because nobody can get there."
I've always taken this as an indication of how Cross got away with everything he did completely scott-free, as he knew he would, being a man of such power, & that this is the way of the world. He's now simply a name, fondly remembered as a founding father of Los Angeles, & his crimes are now either long-buried or completely unknown.
The fact that Earl Rawley says this to Jake can be taken two ways:
- either he doesn't know what kind of a man Noah Cross was, & he regards him as a great man, showing just how the misdeeds of 'great men' can be so easily forgotten;
- or, he knows exactly what kind of a man Noah Cross was, & of his connection to Jake, & this little speech is his way of saying to Jake that powerful men like Noah Cross & himself can do whatever they want, & petty little people like Jake can't do a thing about it. And that nor should they - what Cross & Rawley do is all about progress & the future, & if a few people are hurt along the way, so be it.
I think it's also pretty definite that Cross is dead at the time of The Two Jakes. Katherine appears to be free of him, & if he was still alive he would most likely have some sort of influence over her, either in day to day life, or would at least be doing something about the Berman case. It would also be virtually impossible for her to adopt a new identity if her father was alive.
Whatever happened to Noah Cross wouldn't be a mystery to Jake, or anyone, for that matter - he was a public figure, & easy to keep an eye on. Most likely he died peacefully, of natural causes, not long after the events of Chinatown. If Robert Towne ever had any idea that he came to a bad end, it would almost definitely have been mentioned. Maybe there were further references in earlier versions of the script.
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