Scarlett v Seaboard Coast Line Railroad Company Affidavits and other Evidence in Support of the Motion

Public Court Documents
March 21, 1979

Scarlett v Seaboard Coast Line Railroad Company Affidavits and other Evidence in Support of the Motion preview

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  • Case Files, Cromartie Hardbacks. Fax from Everett RE: Letter to Smiley Concerning Exhibit Lists and Costs, 1999. d723c446-e80e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/b7e4b92a-423e-4d05-8e7e-b7f01b8b4815/fax-from-everett-re-letter-to-smiley-concerning-exhibit-lists-and-costs. Accessed June 14, 2025.

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8799 18:18 Ng.003 P,01 

Received Nov-10-99 11:24am from 9197166763 > LDF 25 

NC a5 SPECIAL LIT Fay T1B676S Mow 10 

EVERETT GASKINS/DURHAM TEL 919-682-5469 Nov © 

      

Everett & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

GLNTE 300 
RO. BYRRETT (1879-1971) 30) W, MAK STREET 

ReRNaoN o. BERET Wali : TEL: (319) 982-869 v i 1 
DAWN T. BATTISTE Dunnam, Nori Carouina 27702 . FAX: (19) 490-5480 
ZAMORA A. HERRING 

CN 

F COUNSEL 
ROBT o HOLEMAN November 8, 199° 

OF COUNBEL 
CRA WM, KABSATTHNICK 
(ADMITTED NL.C.. D.C) 

Ms. Tiare Smiley 
North Caroling Dept. of Justice 
P.O. Box 628 

‘Raleigh, NC 27602-0629 

Deer Tiare: 

With respect to your letters of October 28, 1999 and November 1, 1988, we previously 
responded orally of our agreement to the numbering proposal, Wa will deliver a packet 
tomorrow with copies of many of those documents, The Old Black Second maps are 1 believe 
from Gerry Cohen, and ultimately from the red book in the legislative library, The 1851 
submission portions are chiefly the responses of the State to objections lodged in 1681 by the 
NAACP. The computer log is that Ms, Carraway provided in response to Interrogatory #17 on 
October §, and the second date should be 3/26/97. The nature of the maps and data were more 
fully listed in the Second Draft Exhibit List faxed earlier today. 

With respect to Dr. Peterson's map of Rowatt ¢ounty which you have enhanced and phatocopied, 
we would need to s¢e that map to determine if black and white copying adequately shows the 
segment identification. 

Exhibit 67 is identified on the index to deposition exhibits and it your letters as the 1992 map, 
when [ believe it is the 1997 map, In amy event, we now believe & size A or size B map for the 
exhibits may be sufficiently large, singe the mounted maps will be available for courtroom display. 

Also, I noted that in Supplemental Answer to Interrogatory 18, Senator Cooper téports viewing a 
range of NCEC data which had not previously been disclosed. If any of these reports or a sample 
ISpott remain in existence, we would ask to see them, and may well wish to add them to proposed 
exhibits, either Joint or Plaintiffs’. 

Yours Very Truly, 

Doug ow.

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