Defendants' Supplemental Response to Plaintiffs' First Set of Interrogatories
Public Court Documents
October 15, 1999

4 pages
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Case Files, Cromartie Hardbacks. Defendants' Supplemental Response to Plaintiffs' First Set of Interrogatories, 1999. 205ff5a3-e20e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/7022ae5e-6bb1-43f3-9372-09db52ab6c5d/defendants-supplemental-response-to-plaintiffs-first-set-of-interrogatories. Accessed June 17, 2025.
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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 :