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 November 19, 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