Defendants' Supplemental Response to Plaintiffs' First Set of Interrogatories

    ow we 
UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF NORTH CAROLINA 

WESTERN DIVISION 

Civil Action No. 4-96-CV-104-BO(3) 

MARTIN CROMARTIE, et al., 

Plaintiffs, 

JAMES B. HUNT, JR., in his official 

capacity as Governor of the State of North 

Carolina, et al., DEFENDANTS’ SUPPLEMENTAL 

RESPONSE TO PLAINTIFFS” 
Defendants, FIRST SET OF INTERROGATORIES 

and 

ALFRED SMALLWOOD, et al., 

N
r
”
 

N
a
a
”
 

N
i
e
”
 

N
e
e
?
 

a
t
l
 

N
a
?
 

Sv
at
? 

N
a
w
 

N
w
?
 
i
l
 

S
v
.
 
N
w
?
 

N
w
.
 
N
a
 

N
a
?
 

N
w
?
 

N
w
?
 

Defendant-Intervenors. 

Defendants, by and through counsel, hereby submit the following supplemental responses 

to Plaintiffs’ First Set of Interrogatories, Interrogatory Nos. 11, 15. 21 and 22 

11, During the 1997 session before his plan was presented to the Senate Redistricting 
Committee, Senator Roy Cooper held a meeting with Congresswoman Eva Clayton and 
Congressmen Bob Etheridge, David Price, Mike McIntyre, Bill Hefner and Mell Watt. In addition. 
he met individually with each of these members or representatives from their office, on several 
occasions before the plan was voted on. In addition, Senator Cooper met with Congressman Walter 
Jones in his office in Rocky Mount on at least one occasion before the plan was presented to the 
Senate Committee. Senator Cooper also talked by phone to the members of Congress just mentioned 
in addition to Congressman Coble and Congresswoman Myrick. He believes he may have had a 
discussion with Congressman Burr and Congressman Ballenger or their representatives, but he is 
not sure. He did not talk with or meet with Congressman Taylor. 

15. The National Committee for an Effective Congress (NCEC) provided Senator Cooper 
with some analysis of various plans which he submitted to them. The committee provided statistics 
on population, Democratic performance, the 1990, 1992 and 1996 U.S. Senate Races, the 1988 and 

 



  

wh ww 
1996 Presidential Races, the 1996 Auditor Race, the 1994 and 1996 Congressional Races and 

various registration information by race and political party. This information was provided to 

Senator Cooper on each plan which he submitted to NCEC at various times in 1997 before the final 

plan was voted on. He submitted numerous plans including, but not limited to, each plan which the 

Republican Leadership presented to him, other significant plans offered by members of the public 

and plans offered to him by other members. 

21. See answer to Interrogatory #15. 

22. It is Senator Cooper's understanding that NCEC has ties to the National Democratic 

Party and Senator Cooper received information from NCEC as noted above 

This the 15th day of October, 1999. 

MICHAEL F. EASLEY 

ni Bind, 
(Edwin M. Speas, Jr. 

Chief Deputy Attorney General 

N.C. State Bar No. 4112 

  

Tiare B. Smiley 

Special Deputy Attorney General 

N. C. State Bar No. 7119 

Norma S. Harrell 

Special Deputy Attorney General 

N.C. State Bar No. 6654 

N.C. Department of Justice 

P.O. Box 629 

Raleigh, N.C. 27602 

(919) 716-6900 

 



  

hu ww 
CERTIFICATE OF SERVICE 

This is to certify that I have this day served a copy of the foregoing Defendants’ 

Supplemental Response to Plaintiffs’ First Set of Interrogatories in the above captioned case 

upon all parties by depositing these documents in the United States mail, first class mail, postage 

prepaid addressed as follows: 

Robinson O. Everett HAND-DELIVERY 

Suite 300 First Union Natl. Bank Bldg. 

301 W. Main Street 

P.O. Box 586 

Durham, NC 27702 

ATTORNEY FOR PLAINTIFFS 

Adam Stein U.S. MAIL 

Ferguson, Stein, Wallas, Adkins, 

Gresham & Sumter, P.A. 

Suite 2 

312 W. Franklin Street 

Chapel Hill, NC 27516 

Todd A. Cox 

NAACP Legal Defense & Educational Fund, Inc. 

1444 1 Street NW, 10" Floor 

Washington, DC 20005 

ATTORNEYS FOR DEFENDANT-INTERVENORS 

iare B. Smiley 

Special Deputy Attorney General 

This the 15th day of October, 1999. 

  

~ 
3 

 



w " 
DECLARATION 

Senator Roy A. Cooper, III. Chairman of the Senate Select Committee on Redistricting 

declares and says: 

That I have read the Defendants’ Supplemental Response to Plaintiffs’ First Set of 

Interrogatories and as committee chairman, I am acquainted, at least generally, with the facts 

contained therein as they relate to the Senate or me; that the response was prepared with the advice 

and assistance of counsel; and that the response separately and fully answers each interrogatory. 

except those to which objections are made. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the Defendants’ 

Response is true and correct to the best of my knowledge, information and belief. 

bei fl on 
Senator Roy A. Cooper, III :