Letter from Smiley to All Counsel RE: Joint Appendix

5 pages

Document text

The following text has been generated automatically during the document scanning process. It may contain errors, omissions, or incorrect formatting. Please refer to the PDF document if this text is not usable.

Download

By downloading, publishing, or reusing the Materials outside of the Website, you hereby confirm and attest that you have read and agree to the LDF Archival Collection Terms of Use linked below. We draw your attention to the following:

For those Materials owned by LDF, your use of the Material outside the Site is solely for one or more of the following (the “Permitted Purposes”):

Non-commercial research and private study;
Teaching, scholarship and instruction (including distance learning);
Non-commercial print and non-commercial online use;
Criticism, comment or news reporting; or
For people with visual disabilities (See Section 121 of the Copyright Act).
For those Materials not owned by LDF you understand that:
- It is your responsibility to determine whether the way you plan to use the materials falls within the copyright exception of Fair Use.
- For any use outside of Fair Use, it is your responsibility to seek and obtain all required permissions from any existing rights holders.

LDF hereby grants you the right to use LDF owned Materials for the Permitted Purposes without seeking further permission from LDF.

If you publish or redistribute any Materials (including excerpts and quotes), you must include a credit line and/or proper citation to the source of the Material. However, you may not use the name of LDF in any manner which creates any false association between you and LDF or that incorrectly implies any sponsorship or endorsement of you by LDF.

NOTICE: Uses that do not comply with these Terms or that do not fall under Fair Use (or another exception) may make you liable for copyright infringement.

Read the full LDF Archival Collection Terms of Use Here.

I agree to the terms and conditions for use of this content.

If you would like to use this content in other ways, contact us at

Impact area
- Political Participation
Topic
- Redistricting
LDF Attorneys
Cooperating Attorneys
Organizations
Matter
- Cromartie v. Hunt (Daly v. Hunt)
Case
- Cromartie v. Hunt (Daly v. Hunt)
U.S. state
- North Carolina
Collection
- Case Files
Taxonomy
Identifier
- 1df4c911-e00e-f011-9989-7c1e5267c7b6

Cite this item

Case Files, Cromartie Hardbacks. Letter from Smiley to All Counsel RE: Joint Appendix, 2000. 1df4c911-e00e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/8ac7c08c-050a-42ff-9eda-98424274e193/letter-from-smiley-to-all-counsel-re-joint-appendix. Accessed June 03, 2025.

Copied!

    MICHAEL F. EASLEY 

ATTORNEY GENERAL 

Mr. Robinson O. Everett 

Mr. Martin McGee 

Mr. Doug Markham 

Post Office Box 586 

Durham, NC 27702 

  

State of North Carolina 
Department of Justice 

P.O. BOX 629 : § 
RALEIGH REPLY TO, Tiare B Smiley 

as i" Special Litigation 
27602-0629 (819) 716-6500 

FAX. (919) 716-6763 

July 7, 2000 

VIA U.S. MAIL AND FACSIMILE 

Re: Hunrv. Cromartie Joint Appendix 

Dear Gentlemen: 

Attached please find our first shot at designating materials for the joint appendix. The main 
thing we have not designated is any of Weber's testimony. Since we realize you likely will be 
designating substantial portions of his testimony, we would rather wait to add any additional lines of 
his testimony. Any other additions to the appendix would be minor, and we will get them to you by 
the middle of next week. 

As you are aware, the sooner you can give us your designations, even if piece by piece, the 
better this project will flow. We have agreed that you will give us your designations by July 21, 
2000, with only a few residual items being designated by July 24, 2000. We will continue to 
communicate about maps and tables that are problematic for inclusion in the printed appendix. 

TBS/fa 

CC: Todd Cox 

Adam Stein 

Very truly yours, 

a £ 
Tiare B. Smiley 

Special Deputy Attorney General 

  Ire £9099TL6T6: XS 117 WIJ3dS 99 ON 

£5 

 



  

  

STATE’S JOINT APPENDIX DESIGNATIONS 

Joint Exhibit 100, 1997 Submission 

97C-28F-4D(2) 
97C-28F-4D(3) 
97C-28F-4F(1) pp. 1-4, p. 16 (McMabhan's remarks) 

Defendants’ Exhibit 405, Computer Screen 

Defendants’ Exhibit 411, Computer Screen 

Defendants’ Exhibit 416, Computer Screen 
Defendants’ Exhibit 421, Webster's Report and Tables 

Defendants’ Exhibit 426, Webster’s Supplemental Report with tables; no maps or charts 
Defendants’ Exhibit 429, Peterson’s Third Affidavit 

Detendants’ Exhibit 437, Guilford Precincts Excluded from District 12 

Trial Testimony 

Reuben Oscar Everett 

p. 95, line 4 - p. 97, line 16 

p. 81, lines 12-18 

JH. Froelich 

p- 107, lines 11-22 

Hamilton Horton (Begin T Vol I p. 321) 
p. 35, line 25 - p. 36, line 15 

p. 40, lines 8-12 

p. 42, line 19 - p. 43, line 16 

p. 45, lines 2-9 

John Weatherly 

p. 72, line 8 - p. 77, line 14 

Steven Wood (Begin p. 48) 
p. 62, line 9 - p. 64, line 21 

LI RINEH8 Oy ON 

 



  

Dcposition Transcripts 

Gerry Cohen 
p. 31, line 1 - p. 36, line 19 

. 145, line 2 - p. 146, line 24 

. 15], line 2 - p. 153, line 21 

.172, line 5 - p. 176, line 19 

. 186, line 5 - p. 187, line 2 

. 187, line 22 - p. 188, line 15 

. 194, line 22 - p. 195, line 9 
201, line 23 - p. 202, line 21 

205, line 1 - p. 207, line 14 
243, line 23 - p. 245, line 17 

254, line 12 - p. 258, line 22 

. 293. line | - p. 300, line 3 

.313, line 24 - p. 323, line 10 cr 
JB

 
E
R
R
 

R
R
C
 

RB
 
C
R
 

Roy Cooper 

p. 18, line 12 - p. 19, line 14 

36, line 20 - p. 38, line | 

53.line 5-p. 59, line 6 

62, line 9 - p. 66, line 11 

70, line 25 - p. 72, line 19 

74, line 17 - p. 76, line 6 

.77, line 7 - p. 78, line 11 

. 104, line 4 - p. 109, line 25 

. 112, line 11 - p. 114, line 18 

. 128, line 20 - p. 131, line 18 

. 132, line 6 - p. 133, line 22 TT
 

WP
 
VY
 

VU
 

BT
 

Linwood Lee Jones 

p. 64, line 24 - p. 67, line 14 
p. 112, line 6 - p. 114, line 24 

p. 118, line 4 -p. 119, line 10 

William Edwin McMahan 

. 25, line 2] - p. 28, line 2 

. 34, line 19 - p. 35, line 6 

. 36, line 3 - p. 39, line 8 

. 40, line 6 - p. 41, line 12 

. 46, line 22 - p. 48, line 23 

. 78, line 25 - p. 79, line 13 

. 93, lines 7-22 

. 98, line 20 - p. 101, line 20 

Pp 

P 

P 

Pp 

P 

P 

P 

P 

FO 'd 65:71 « QO, 2 IT $9.991.616: 1&4 117 WI734S 90 IN 

 



p. 109, line 22 - p. 110, line 14 
? 

Gerald R. Webster 

p. 49, line 16 - p. 50, line 11 

p. 79, line 20 - p. 81, line 9 

$9.9ITLET6: XE L111 W345 S90 ON  



    
State of North Carolina 

MICHAEL F. EASLEY Department of Justice 
J 7 D 

ATTORNEY GENERAL P.O BOX 629 REPLY TO: Tiare B. Smiley 

RALEIGH 
¢' xs F'xbrivry 1 Special Litigation 

276020629 
(918) 716-6900 

FAX: 919) 716-6763 

TELECOPIER TRANSMITTAL SHEET 

TO: Robinson O. Everett 

Fax: (919) 682-5469 

Martin McGee 

Fax: (704) 932-9597 

Todd Cox 

Fax: (202) 682-1312 

Adam Stein 

Fax: (919) 967-4953 

FROM: Tiare B. Smiley, Special Deputy Attorney General 

TELEPHONE NUMBER: (919) 716-6900 

DATE: July 7, 2000 

SUBJECT: Attachment - Designations 

NUMBER OF PAGES INCLUDING TRANSMITTAL SHEET: 4 

CONFIRM RECEIPT OF DOCUMENT(S) IF MARKED HERE: 

COMMENTS: 

CONFIDENTIALITY NOTE 
  

THE INFORMATION CONTAINED IN THIS FACSIMILEMESSAGEIS LEGALLY PRI VILEGED AND 

CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDI VIDUAL OR 

ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED 

RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION. DISTRIBUTION OR 

COPY OF THIS TELECOPY IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS 

TELECOPY IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE AND RETURNTHE 

ORIGINAL MESSAGE TO US AT THE ADDRESS ABOVE VIA UNITED STATES POSTAL 

SERVICE. THANK YOU. 

10°d 2e:ple O00, 4 1 929972616: <k 4 117 WIJ3d4S 9b ON

Copyright notice

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.

Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.

Letter from Smiley to All Counsel RE: Joint Appendix

Impact area

Topic

LDF Attorneys

Cooperating Attorneys

Organizations

Matter

Case

U.S. state

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

You may also be interested in