Letter to Everett from Smiley RE: Deposition exhibit costs

    State of North Carolina 
MICHAEL F. EASLEY Department of Justice 

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

RALEIGH Special Litigation 
27602-0629 (919) 716-6900 

FAX: (919) 716-6763 

November 1, 1999 

BY FACSIMILE AND U.S. MAIL 

Mr. Robinson O. Everett 

Everett & Everett 

Post Office Box 586 

Durham, NC 27702 

Mr. Doug Markham 

c/o Everett & Everett 

Post Office Box 586 

Durham, NC 27702 

Re: Cromartie Deposition Exhibit Costs 

Dear Robinson and Doug: 

For your information, we have asked DocuTrust to provide us with cost estimates for 
preparing three sets of tabbed notebooks and copies of deposition exhibits for the Court. That 
information is enclosed. 

We also need to be thinking about stipulated exhibits. Although we may agree to stipulate 
to many of the numerous maps you have listed, there are only a limited number for which we will be 
willing to share the costs. If you had a more limited list, it might be reasonable to get some duplicates 
from the General Assembly’s Information Services Division, although they likely would charge for 
the copies. However, it seems unreasonable to expect the General Assembly staff to provide you 
three to five copies of all the maps you have listed. If you wish to have DocuTrust prepare the 
stipulated exhibit notebooks, we would anticipate sharing costs in a manner similar to that for the 
deposition exhibits. Because of the high cost of providing color copies of large maps, we are going 
to use only a black and white copy of the one Peterson segment map we discussed earlier. 

Another alternative would be for defendants to provide you three copies of defendants’ 
designated deposition and stipulated exhibits, which you can put into notebooks for the Court. Please 
let us know as soon as possible your thoughts on providing these exhibits for the Court. Obviously, 

 



  

Mr. Robinson O. Everett 

Mr. Doug Markham 

November 1, 1999 

Page 2 

the parties will be responsible for their own exhibits. 

Finally, we need a more final version of your deposition and stipulated exhibit list which 
deletes duplicates and provides a column for objections. We want to finalize our exhibits and begin 
preparing notebooks, but cannot move forward until we know exactly which exhibits, especially 
maps, you will be using and have verified they are what we think they are. 

We think we need to meet and firm up some of these kinds of details as soon as possible. 

Sincerely, | 

ut Gr 
Tiare B. Smiley 

Special Deputy Attorney General 

TBS\fa 

CC: Adam Stein 

Todd Cox 

 



  

PROPOSAL FOR REPRODUCING DEPOSITION EXHIBIT NOTEBOOKS 
FOR THE COURT 

AND SHARING THE COST OF SAME 

DocuTrust will reproduce the Deposition Exhibits at a bulk rate and will deliver three sets of 
assembled notebooks to the parties at a date to be specified for the following prices: 

$.06 per 81/2 x 11" page, black and white 
$.18 per tab 

$11.00 per 3" notebook (2 for each set totaling 6) 

The cost of Exhibit 31 - the oversized spreadsheet will be approximately $4.00 per page. 

The cost of Exhibit 54 - 81/2 x 11" color map with districts drawn by Linville will be 
approximately $.84 per copy. 

The oversized map exhibits listed below will be approximately $86.00 per copy: 

Exhibit 13 Evolution of Congressional District 1 
Exhibit 14 Evolution of Congressional District 12 
Exhibit 60 Precinct Map of Rowan County (enlargement of Exhibit 61) prepared by Everett 
Exhibit 61 Precinct Map of Rowan County, prepared by Everett 
Exhibit 67 North Carolina Congressional Plan (1992) 
Exhibit 69 Voter Precincts as Recorded in the Plan90 Apportionment System 
Exhibit 70 1990 Minor Civil Divisions (Townships) for North Carolina Counties 

Defendants have designated Deposition Exhibits 42, 43, 44 and 63, which total 38 pages 
and 4 tabs, or a total of approximately $9.00. Defendants will pay for one-half of the notebooks 
or $33.00, for a total of $42.00. Defendants will provide copies of Exhibit 66, the North 
Carolina Department of Transportation Road Maps. 

DocuTrust is located at Suite 960, Two Hanover Square, Raleigh, NC 27601, telephone 
919-833-2679. We previously have used their services and believe their rates are at or below 
other providers.