Memo to Stein RE: Cromartie Written Discovery

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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
- 0d038f23-ee0e-f011-9989-7c1e5267c7b6

Cite this item

Case Files, Cromartie Hardbacks. Memo to Stein RE: Cromartie Written Discovery, 1999. 0d038f23-ee0e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/2c775048-295a-4928-9bbf-2ae01b109b46/memo-to-stein-re-cromartie-written-discovery. Accessed November 23, 2025.

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MEMORANDUM

Adam Stein

Todd Cox PL

Cromartie Written Discovery

September 30, 1999

Attached is the State’s draft responses to Plaintiffs’ First Request for Admissions. In

general, I do not disagree with the State’s responses. However, I have concerns with a few

specific responses and I think the State should modify accordingly. In any event, I think we

should respond differently. My concerns with the admissions are outlined below:

Response to Admission 6: I do not think the State should specifically identify the

characteristics of the district that made it vulnerable to constitutional attack or even concede that

it was vulnerable to attack. Such an admission/concession would prevent it from using any of

these methods in redistricting in the future and unnecessarily taint the 1997 Plan to the extent they

argue that any of the 1992 Plan is the “core” of the 1997 Plan. I think it is enough to admit that

the 1992 Plan was attacked and that the Court held it unconstitutional and deny everything else.

Response to Admission 13: I do not think that it is necessary to specify that black and

white candidates rely on the votes of black voters, as it could lead to Vera-type allegations. The
balance of the admission is sufficient.

Response to Admission 22: In addition to Section 2, I think that the State should list the

effect and purpose prongs of Section 5 as possible grounds for a Civil Rights Division objection.

Response to Admission 27 and 28: 1 do not think it helps the State to admit that

Districts 1 and 12 of the 1992 Plan are not compact. I think that it could in fact help to dignify

Everett’s “fruit of the poisonous tree” argument, since the State is arguing that the 1997 districts

use the core of the prior district.

I have also attached the interrogatory answers I drafted. Tiare and I agreed that I would

take the lead on answering the first 3 interrogatories and the State would take the lead on the

others. I will contact you soon. Thanks.

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Memo to Stein RE: Cromartie Written Discovery

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Case

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