Letter from Everett to Smiley RE: Stipulations

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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
- be4230db-e80e-f011-9989-7c1e5267c7b6

Cite this item

Case Files, Cromartie Hardbacks. Letter from Everett to Smiley RE: Stipulations, 1999. be4230db-e80e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/219a58a3-7ab1-4e48-bfa2-3aaeba2dd212/letter-from-everett-to-smiley-re-stipulations. Accessed November 19, 2025.

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    EVERETT GASKINS/DURHAM TEL :919-682-5469 Novy:23°9 12:59 N0.010 P.O2 

EVERETT & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

SUITE 300 
" A.O. EVERETT (1878-1971) 301 W. MAIN STREET 
KATHRINE R. EVERETT (1893-1992) 
ROBINSON O. EVERETT P.O. 80x 568 
DAWN T. BATTISTE DurHAM, NoRTH CAROLINA 27702 FAX: (910) 583-5480 
SANDRA Q. HERRING 

OF COUNSEL 
ROBERT D. HOLLEMAN 

OF COUNSEL 
CRAIG M. KABATCHNICK 
(ADMITTED N.C., D.C) November 23, 1999 

Ms. Tiare Smiley 
N.C. Department of Justice 
P.O. Box 629 

Raleigh, NC 27603 

Dear Tiare, 

We proposed a number of stipulations as to division between African-American and white 
populations in various cities and counties that were split in the 12 District. You rejected a large 
number of those. In light of the court’s desire to get on with business and not retrace its steps, I 
would propose this stipulation: “The parties agree that the statistics and numbers pertaining to the 
divisions of cities, counties, and political precincts stated in the vacated summary Judgment 
memorandum opinion of April 14, 1998 are accurate.” If any of those statistics are inaccurate, 
please identify them and they can be excluded from the stipulation. 

In my opinion, adoption of such a stipulation would be quite desirable from the standpoint 
of saving time for the court and will eliminate a number of individual stipulations or offers of 
proof. I would appreciate your responding forthwith to this suggestion, since we are in the last 
stages of revising our stipulations. 

Sincerely, 

Ul gre 
Robinson O. Everett 
Attomey for Plaintiffs 

  

TEL: (910) 882-5691



      

EVERETT GASKINS/DURHAM TEL 913-682-5469 Nay 23°99 ® No.0l10 P.O1 

EVERETT & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

SUITE 300 

R.O, EVERETT (1878-1971) 301 W. MAIN STREET 
KATHRINE R. EVERETT (1892-1892) P.O. BOX 586 
ROBINSON O. EVERETT TEL: (919) 682-5681 
DAWN T. BATTISTE DurHam, NorTH CaroLINA 27702 FAX: (019) 832.5460 
SANDRA G. HERRING 

  

OF COUNSEL 
ROBERT 0. HOLLEMAN 

OF COUNSEL 
CRAIG M, KABATCHNICK 
(ADMITTED N.C. D.C.) 

To. Ms. Tiare Smiley, via fax to 716-6763 
Mr. Adam Stein, via fax to 967-4953 
Mr. Todd Cox, via fax to 202-682-1312 

From: Robinson Everett, Marty McGee, Doug Markham or Seth Neyhart 

Subject: (eters ser 

Date: November £3 | 1999 

Approximate Pages: 3

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Letter from Everett to Smiley RE: Stipulations

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