Letter to Everett From Harrell RE: Request for Mortimer Deposition and Scheduling Other Depositions

Correspondence
September 20, 1999

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Letter to Everett From Harrell RE: Request for Mortimer Deposition and Scheduling Other Depositions 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
- cc58337e-e20e-f011-9989-002248226c06

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Case Files, Cromartie Hardbacks. Letter to Everett From Harrell RE: Request for Mortimer Deposition and Scheduling Other Depositions, 1999. cc58337e-e20e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/5a994c60-e138-4979-a13d-85c4e3c8b898/letter-to-everett-from-harrell-re-request-for-mortimer-deposition-and-scheduling-other-depositions. Accessed November 19, 2025.

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State of North Carolina

MICHAEL F. EASLEY Department of Justice

ATTORNEY GENERAL P.O. BOX 629 REPLY TO: Norma S: Harrell

RALEIGH Special Litigation

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

September 20, 1999

BY HAND DELIVERY

Mr. Robinson O. Everett

Everett & Everett

Post Office Box 586

Durham, NC 27702

Re: Request For Mortimer Deposition & Concerns Re: Scheduling Other Depositions

Dear Robinson:

Please have Lee Mortimer bring to his deposition ( or furnish to us in advance) the following

materials:

L His most recent resume;

2 Copies of all articles he lists in his report as having been written by him and any other

recent articles by him relevant to his testimony or expertise;

3. Copies of all data (including statistics on population, voting age population, election

results, and registration) for each of the districting plans reproduced in his report.

As to the scheduling of depositions of your clients and witnesses, we must get those scheduled

very quickly. From our point of view, the available dates are Tuesday the 28th, Wednesday the 29th,

Thursday the 30th, and Monday the 4th. This Thursday, the 23d, would also be available from our

point of view and perhaps the afternoon of this Friday, the 24th, for here in Raleigh. Please talk to

your clients and witnesses and propose specific dates on which you know they can be present here or

at another appropriate location. For the plaintiffs and other witnesses whose depositions are likely

to be short, please propose specific appropriate dates and locations for which you know an appropriate

number of them can be available.

As to moving Linwood Jones’ deposition to Wednesday, he is willing to rearrange his

schedule to make that possible. Ms. McGovern is probably not personally available, but will be able

to provide a court reporter. As an alternative, we could move Linwood Jones’ deposition to earlier

Mr. Robinson O. Everett

September 20, 1999

Page 2

on Tuesday morning if your schedule permits or if one of your colleagues can take the deposition.

Ms. McGovern is available at any time Tuesday morning as a result of a change in her schedule. We

will be glad to take Mr. Cromartie’s deposition on Wednesday afternoon after you take Mr. Jones’

or just by itself.

Thank you for your prompt attention to these matters.

Sincerely,

Hons Ae”
Norma S. Harrell

Special Deputy Attorney General

ce: Adam Stein

Todd Cox

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Letter to Everett From Harrell RE: Request for Mortimer Deposition and Scheduling Other Depositions

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