Fax from Smiley to opposing counsel RE: Pretrial order exhibit list and numbering

Correspondence
October 28, 1999

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Fax from Smiley to opposing counsel RE: Pretrial order exhibit list and numbering preview

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Impact area
- Political Participation
Topic
- Redistricting
Matter
- Cromartie v. Hunt (Daly v. Hunt)
Case
- Cromartie v. Hunt (Daly v. Hunt)
U.S. state
- North Carolina
Collection
- Case Files
Taxonomy
Identifier
- ea512789-010f-f011-9989-7c1e5267c7b6

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Case Files, Cromartie Hardbacks. Fax from Smiley to opposing counsel RE: Pretrial order exhibit list and numbering, 1999. ea512789-010f-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1ad47c5d-2f75-4469-a6cb-93aeef97ba70/fax-from-smiley-to-opposing-counsel-re-pretrial-order-exhibit-list-and-numbering. Accessed November 19, 2025.

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MICHAEL F. EASLEY

ATTORNEY GENERAL

State of North Carolina
Department of Justice

P.O. BOX 629 REPLY TO: Tiare B. Smiley
RALEIGH Special Litigation

27602-0629 (919) 716-6900
FAX: (919) 716-6763

October 28, 1999

BY FACSIMILE AND U.S. MAIL

Mr. Robinson O. Everett

Everett & Everett

Post Office Box 586

Durham, NC 27702

Mr. Doug Markham

c/o Everett & Everett

Post Office Box 586

Durham, NC 27702

Re: Pretrial Order Exhibit List and Numbering

Dear Robinson and Doug:

There are several exhibits we need copies of as soon as possible, as well as other exhibits we

need to see to verify we are talking about the same map or document. In addition, even after

removing the duplications you have got too many maps to fit within the 100 range of numbers.

Because we want to start numbering and copying our exhibits we would propose the following new

allocation of numbers:

1-99

100-299

300-399

400-499

500-599

Deposition Exhibits

Stipulated Maps and Data

Plaintiffs’ Exhibits

Defendants’ Exhibits

Defendant-Intervenors’ Exhibits

This numbering should work even if several groups of maps end up moving from the stipulated

exhibits to plaintiffs’ exhibits. Intervenors agree with this proposal. We would like a response on

the numbering issue today if possible.

Mr. Robinson O. Everett

Mr. Doug Markham

October 28, 1999

Page 2

Nos. 169-187

Exhibits Needed

Maps and Possible Joint Exhibits

Nos. 196A-196H, 197A-197H

Nos. 198A-198C

Nos. 199C and 199D

No. 199F

No. 199H

No. 1991

No. 199]

Nos. 199K-Q

Nos. 200-210

211

. 211 [sic]

213

.214

+213

. 216

217

219

Plaintiffs’

Maps from NC State Center for Geography

Election Returns

Maps “highlighting” Old Black Second

1970 and 1980 Congressional Districts (If we knew the

source of these maps we might only need to verify.)

“Selected” portions of 1991 Submission

Winner remarks (Need source and date to verify - if

you have reformatted from an original source, we will

need a copy of your exhibit.)

Computer log 6/28/93 through 6/26/97 (Need to

verify.)

Election Returns

Maps and Data for various plans (We need the source

and to verify we are using the same maps (black and

white, size, etc.) and same reports.)

Proposed Exhibits

Demographic and Partisan Data (We need the source

and to verify we are using the same reports.)

Almanac of American Politics for 1998

Morrill/Charlotte Observer Plan and data

Groffman Law Review article

R. L. Morrill publication

R. L. Morrill article

UPI story April 21, 1984

Mr. Robinson O. Everett

Mr. Doug Markham

October 28, 1999

Page 3

This list was put together rather hastily, so there may be other exhibits for which we need

copies. In addition, at some point we probably would like to verify all the exhibits, especially maps,

to assure we have exact copies. It is likely that defendant-intervenors will need copies of all of your

exhibits, but you can work that out with them.

Sincerely,

ie Bh
Tiare B. Smiley

Special Deputy Attorney

TBS\sp

CC: Adam Stein

Todd Cox

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Fax from Smiley to opposing counsel RE: Pretrial order exhibit list and numbering

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