Application to Exceed Page Limit

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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
- d0a098f0-e10e-f011-9989-002248226c06

Cite this item

Case Files, Cromartie Hardbacks. Application to Exceed Page Limit, 2000. d0a098f0-e10e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/913ca245-c2cf-4850-9bdc-a940cea94fcb/application-to-exceed-page-limit. Accessed November 19, 2025.

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Nos. 99-1864 and 99-1865

In the

Supreme Court of the United States

JAMES B. HUNT, JR., et al.

Appellants,

and

ALFRED SMALLWOOD, et al.

Appellant-Intervenors

MARTIN CROMARTIE, et al.

Appellees.

ON APPEAL

APPLICATION TO EXCEED PAGE LIMIT

To the Honorable William H. Rehnquist, Chief Justice of the United States and Circuit

Justice for the Fourth Circuit:

Pursuant to Supreme Court Rule 33(1)(d), Appellees respectfully apply for an extension

by 10 pages of the length allowed for their Brief on the Merits. In support of their application

Appellees show the Court the following:

(1) The appeal arises in a very extensive factual record and the facts required detailed

discussion.

(2) Appellants and Appellant-Intervenors have submitted lengthy Briefs on the

Merits, 50 and 36 pages respectively, and two amici, the Solicitor General and the

ACLU, have also submitted extensive briefs of 30 pages each.

3) Despite extensive efforts by Appellees to prepare a Brief on the Merits that will be

for no more than 50 pages in length and will adequately cover the issues, they

have been unable to do so.

4) Appellants’ Counsel of Record has indicated through her paralegal that Appellants

oppose this Application to Exceed Page Limit. Counsel for Appellees attempted

to contact Counsel of Record for Appellant-Intervenors the morning of October 2,

2000, but these attempts were unsuccessful.

(5) Because of the “extraordinary circumstances” it will be in the interest of justice to

allow Appellees’ requested extension of length by up to ten pages.

Wherefore Appellees respectfully pray that their Application to Exceed Page Limit to 60

Pages be granted.

Respectfully submitted this 2" day of October, 2000

slovenia
Ry: LIA A. 7lybhats

ROBINSON O. EVERETT ¢
(Counsel of Record)

SETH A. NEYHART

EVERETT & EVERETT

P.O. Box 586

Durham, NC 27702

(919) 682-5691

a
o

MARTIN B. MCGEE

WILLIAMS, BOGER, GRADY,

DAVIS & TUTTLE

708 McClain Rd.

Kannapolis, NC 28081

(704) 932-3157

DOUGLAS E. MARKHAM

P.O. Box 130923

Houston, TX 77219-0923

(713) 655 - 8700

CERTIFICATE OF SERVICE

I certify that I have this day served the foregoing Application to Exceed Page Limit by fax

and by U.S. mail to the following addresses:

Ms. Tiare B. Smiley, Esq.

Special Deputy Attorney General

North Carolina Department of Justice

114 W. Edenton St., Rm 337

P.O. Box 629

Raleigh, NC 27602

Phone # (919) 716-6900

Mr. Todd A. Cox
NAACP Legal Defense & Educational Fund, Inc.

1444 Eye Street, NW 10" Floor
Washington, DC 20005

(202) 682 -1300

This the 2™ day of October, 2000

Postar OC
Bre Jo ZX. JlopharX™

Robinson O. Everett /

Lead Counsel for Appellees

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Application to Exceed Page Limit

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Matter

Case

U.S. state

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

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