Letter to Markham from Smiley RE: Exhibits Issues
Correspondence
November 16, 1999

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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® ® Sy ® \ 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