Letter to Everett From Smiley RE Cromartie Depositions and Discovery

Correspondence
September 2, 1999

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Letter to Everett From Smiley RE Cromartie Depositions and Discovery 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
- aef8555d-f80e-f011-9989-7c1e5267c7b6

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Case Files, Cromartie Hardbacks. Letter to Everett From Smiley RE Cromartie Depositions and Discovery, 1999. aef8555d-f80e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/2a088c8a-b63f-4577-9bf9-50eeff02a478/letter-to-everett-from-smiley-re-cromartie-depositions-and-discovery. Accessed November 21, 2025.

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State of North Carolina

MICHAEL F. EASLEY Department of Justice

ATTORNEY GENERAL P.O. BOX 629 REPLY TO Tiare B. Smiley

RALEIGH Special Litigation

- ~ (919) 716-6900 0629
prego0n FAN (919) 716-6763

September 2. 1999

Mr. Robinson O. Everett

Everett & Everett

Post Office Box 586

Durham. NC 27702

Re: Cromartie Depositions and Discovery

Dear Robinson:

You requested today that we reschedule the deposition of Gerry Cohen from September 17

to September 15. However, as | told Douglas Markham, I have an argument in a capital case in the

North Carolina Supreme Court on September 16, and upon reflection will need September 15 to

prepare. [am sorry that the September 17 date you originally proposed will not work for you. I have
previously informed Douglas that Gerry Cohen will not be available on September 23. 24 or 30 or
October 1. Either September 21. 22 or 23 is acceptable for a trip to the Piedmont to depose plaintiffs

from that part of the state, although you may want to schedule Gerry Cohen for the September 21 or
22

With regard to your interrogatories, we will not know until after we gather information and

begin preparing written responses the extent of objectional interrogatories. although a brief review

seems to indicate there are a few. It appears to us that a reasonable compromise is for you to agree
to eliminate about five additional discrete questions or subparts. If you prefer to involve the court
instead of reaching a mutually acceptable solution, please let us know.

Sincerely, :

Tiare B. Smiley

Special Deputy Attorney Genera

TBS/fa

cc: Adam Stein

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Letter to Everett From Smiley RE Cromartie Depositions and Discovery

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