Letter to Markham from Harrell RE: pretrial order

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Impact area
- Political Participation
Topic
- Redistricting
Matter
- Cromartie v. Hunt (Daly v. Hunt)
Case
- Cromartie v. Hunt (Daly v. Hunt)
U.S. state
- North Carolina
Collection
- Case Files
Taxonomy
Identifier
- cc6abca4-e10e-f011-9989-7c1e5267c7b6

Cite this item

Case Files, Cromartie Hardbacks. Letter to Markham from Harrell RE: pretrial order, 1999. cc6abca4-e10e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/7d7018d1-0702-4de5-9358-d442719614a3/letter-to-markham-from-harrell-re-pretrial-order. Accessed November 19, 2025.

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NC AG SPECIAL LIT ¢ :9197166763 Nou 22 199 22:17 P.O

State of North Carolina

MICHAEL F. BEASLEY Department of Justice

ATTORNEY GENERAL P. QO. BOX 629 REPLY TO: Norma S. Harrell

RALEIGH Special Litigation

27602-0629 (919) 716-6900
FAX: (919) 716-6763

November 22, 1999

BY FACSIMILE AND U.S. MAIL

Mr. Doug Markham

c/o Everett & Everett

Post Office Box 586

Durham, NC 27702

Re: Pretrial Order

Dear Doug:

After reviewing your designationsas to R. O. Everett and Jake Froelich, and considering what

we would then want to designate, it looks as if we would have virtually the entire depositions

designated if their depositions are to be used essentially in lieu of trial testimony. Therefore, we plan

simply to designate the entire depositions even though there will be a few pages that will be
unnecessary or unwanted by either side. Assuming you plan to offer testimony from Joel Bourne's

deposition in a similar manner, we would do the same thing for his deposition in all probability.

Sincerely,

Nos of thont!”
Norma S. Harrell
Special Deputy Attorney General

eC: Adam Stein

Todd Cox

NC AG SPECIAL LIT Fax:9197166763 Nov 22 ’99 22:18 P.O?
DESIGNATIONS OF DEPOSITIONS

Reuben Oscar Everett, entire deposition

Jacob Henry Froelich, Jr., entire deposition

Joel K. Bourne, entire deposition

ROBINSON O, EVERETT
DAWN T. BATTISTE DurHam, NoaTtH Carolina 27702
SANDRA GQ, HERRING

EVERETT & EVERETT
ATTORNEYS AND COUNSELORS AT LAW

SUITE 300

R.O. EVERETT (1878-1971) 301 W, MAIN STREET
KATHRINE R, EVERETT (1893-1902) P.O. BOX 686

OF COUNSEL
ROBERT D, HOLLEMAN November 22, 1999

OF COUNSEL

CRAIG M, KABATCHNICK
(ADMITTED N.C., D.C.)

Ms. Norma S. Harrell Via Fax to 716-6763

State of North Carolina

Attorney General's Office
PO Box 629

Raleigh, NC 27609-0629

Re: Offer from Mr. Bourne’s deposition

Dear Norma:

These are the pages we expect to offer from the deposition of Mr. Bourne:

Page 4, line 21 to Page S, line 11

Page 27, line 14 to 23
Page 38, line 24 to Page 39, line 14
Page 40, line 15 to Page 42, line 21

Page 44, line 21 to Page 45, line 5

page 47, line 20 to Page 49, line 22

Page 50, line 24, to Page 51, line 4

Page 57, line 14 to Page 58, line 14
Page 59, line 5 to 14

page 64, line 8 to 21
Page 65, line 17 through Page 66, line 12

Yours Very Truly,

Douglas Markham

op: Mr. Adam Stein, via fax to 967-4953

: Mr. Todd Cox, via fax to 202-682-1312

EVERETT GASKINS DURHAM 20 Noy 22°99 15:41 No .013 P.0O1

TEL: (910) 882-5891
FAX: (019) 882-5460

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Letter to Markham from Harrell RE: pretrial order

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