Letter to Markham from Smiley RE: Exhibits Issues

Correspondence
November 16, 1999

Letter to Markham from Smiley RE: Exhibits Issues preview

4 pages

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  • Case Files, Cromartie Hardbacks. Letter to Markham from Smiley RE: Exhibits Issues, 1999. 4df50979-e50e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/700ba246-abc5-4152-9a7b-75463660b884/letter-to-markham-from-smiley-re-exhibits-issues. Accessed June 14, 2025.

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State of North Carolina’ 

MICHAEL F. EASLEY Department of Justice 
ATTORNEY GENERAL x P.O. BOX 629 REPLY TO: Tiare B. Smiley 

RALEIGH Special Litigation 

is (919) 716-6900 2 062 
gUe020az9 FAX: (919) 716-6763 

November 16, 1999 

BY FACSIMILE AND U.S. MAIL 

Mr. Doug Markham 

c/o Everett & Everett 

Post Office Box 586 

Durham, NC 27702 

Re: Cromartie - Exhibits Issues 

Dear Doug: 

We believe we have identified most of the issues from your Second Draft Exhibit List. 
Attached are our comments on exhibits we do not have copies of or which we need to review and 
compare to determine if we are referring to the same document. We also have tried to note which 
exhibits we will not stipulate as joint exhibits. We did not repeat the comments on exhibits listed in 
our November 12. 1999 letter so that those problems remain outstanding. Please note, that when we 
refer to size D maps, we are referring to the General Assembly’ssize D or 2 x 3 feet. Although there 
are some maps that we will stipulate as joint exhibits, where they are being designated by plaintiffs 
we consider them to be plaintiffs’ responsibility. We need another draft of the exhibit list that is 
closer to a final draft so that we can resolve who is responsible for what. 

Finally, we would like to put exhibit numbers on our exhibits and finalize exhibit notebooks. 
It would be useful if the parties could meet to review and compare one full set of all exhibits to assure ; 
that we are referring to the same document and to designate a final exhibit number. It will then be 
possible to work out the number of copies needed and to prepare notebooks. We would like to have 

 



  

Mr. Doug Markham 

November 16, 1999 

Page 2 

all our exhibits and notebooks completed before Thanksgiving, so we would like to meet with 
documents in hand this week. 

“ 

Sincerely, 

/ PSY 

iare B. Smiley 

Special Deputy Attorney Ge 
TBS/fa 

cc: Adam Stein 

Todd Cox 

 



11/16/99 UPDATE ON EXHIBIT LIST ISSUES 

Exhibits 101A-C 

Exhibits 102, 103, 104 

Exhibits 105A-D, 106A-D 

Exhibit 107A-B 

Exhibit 108 

Exhibit 109 

Exhibit 110 

Exhibits 111-114 

Exhibits 115, 117-125 

Exhibits 127-129, 131 

Exhibits 130, 132, 133 

Exhibits 135-143 

Exhibit 145 

Exhibits 144, 146-149, 151 

Exhibits 153, 154, 158 

Exhibit 162 

Exhibit 163 

Exhibits 164-167 

Exhibits 169-171 

Exhibits 188-195 

We have copies; we will not stipulate as a joint exhibit. (We need to 
review-and compare.) 

We need to review and compare; okay as joint exhibit. 

We will provide copies; okay as joint exhibit. (Our maps are in color; 
you may want to review and compare.) 

Has not been provided; will not stipulate as a joint exhibit. 

We have size D; will not stipulate as joint exhibit. 

Has not been provided; will not stipulate as a joint exhibit. 

We have size D; will not stipulate as joint exhibit. 

We have size D; okay as joint exhibit. 

We have size D; will not stipulate as joint exhibit. 

We have size B; will not stipulate as joint exhibit. 

‘We have size D; will not stipulate as joint exhibit. 

We have size B; will not stipulate as joint exhibit. 

Has not been provided; will not stipulate as joint exhibit. 

We have size D; will not stipulate as joint exhibit. 

We have size B; will not stipulate as joint exhibit. 

We have size D; will not stipulate as joint exhibit. 

Has not been provided; will not stipulate as joint exhibit. 

We have size B; will not stipulate as joint exhibit. 

Have not been provided; will not stipulate as joint exhibit. 

Have not been provided (we will want to see how they copy); okay 
as joint exhibit.  



  

Exhibits 196A, 196B, 

193, 199 

Exhibit 204 

Exhibits 209-220 

Exhibits 221A-D 

Exhibit 222A-C 

Exhibit 223 

Exhibits 224A-C, 226A-B 

Exhibits 227A-B, 228A-C 

Exhibits 237, 238 

Exhibit 239 

Exhibit 240 

Please add these exhibits: 

Exhibit 16 

Exhibit 31 

Exhibit 74 

Have not been provided; cannot determine if a joint exhibit or not. 

Has not been provided; cannot determine if a joint exhibit or not. 

1999 split precinct maps - We have size B; will not stipulate as joint 

exhibits. 

Have not been provided; may be okay as joint exhibit. 

We will provide copies; okay as joint exhibit. (Our maps are in color; 

you may want to review and compare.) 

No description - Has not been provided. (You deleted Deposition 

Exhibit 40 as subsumed in 223.) May be okay as joint exhibit. 

Have not been provided; may be okay as joint exhibit. 

We will provide copies; okay as joint exhibit. (Our maps are in color 

and you may want to review and compare.) 

Have not been provided; cannot determine if a joint exhibit or not. 

We have August 1999 copy; will not stipulate as a joint exhibit. 

We have this triple map from 98C-27A-3C (unique size); okay as 

joint exhibit, except delete editorial description as “evolution.” 

DEPOSITION EXHIBITS 

Cohen e-mails 2/2/97 - 3/20/97 

Spreadsheet showing District 2 election and registration data. 

Shaw, et al. v. Hunt, et al., Order to file an Amended Complaintto add 

new plaintiffs and plaintiff-intervenors, 7/12/96

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