Gooden v. Mississippi State University Supplemental and Reply Brief in Support of Certiorari
Public Court Documents
January 1, 1974

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Case Files, Cromartie Hardbacks. Letter to Everett RE: Difficulty providing requested information at Dr. Baker’s deposition, 1999. 8caafde4-f20e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/c977a308-6cd8-49b6-814e-c41e4d54444b/letter-to-everett-re-difficulty-providing-requested-information-at-dr-baker-s-deposition. Accessed August 19, 2025.
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Regional Office 1444 Eye Street, N.W., 10th Floor A A NAACP LEGAL DEFENSE AND Washington, D.C. 20005 EDUCATIONAL FUND, INC. 202-682-1300 202-682-1312 Fax October 6, 1999 By Hand Delivery Robinson O. Everett Everett & Everett 301 W. Main Street P.O. Box 586 Durham, North Carolina 27702 Dear Mr. Everett: This is in response to your letter dated October 5, 1999, a telefacsimile copy of which I received the afternoon of October 5th. You have requested that I have Mr. Baker bring a number of items to his deposition this Thursday, October 7, 1999. For the following reasons, it may not be possible to comply with your request. Although defendants and defendant-intervenors notified you that Mr. Baker would be a potential witness on September 22, 1999, your document request arrived less than two days before Mr. Baker’s deposition this Thursday. Such late notice is entirely unreasonable. However, it is made all the more burdensome given Mr. Baker’s schedule this week. Mr. Baker is engaged currently in efforts to help the victims of flooding in the eastern part of North Carolina. Therefore, on such short notice, it will be very difficult for Mr. Baker to search for and/or retrieve the documents you requested. Nevertheless, Mr. Baker has indicated that he will make an effort to bring to his Thursday deposition any materials he is able to retrieve. Todd A. Cox oC; Adam Stein Tiare B. Smiley The NAACP Legal Defense and Educational Fund, Inc. (LDP is not a part of the National ~~ National Office Regional Office Association for the Advancement of Colored People (NAACP) although LDF was founded ~~ 99 Hudson Street, Suite 1600 315 West 9th Street, Suite 208 by the NAACP and shares its commitment to equal rights. LDF has had, since 1957, a separate ~~ New York, NY 10013-2897 Los Angeles, CA 90015 board, program, staff, office and budget. Contributions are deductible for U.S. income tax purposes. 212-965-2200 212-226-7592 ax 213-624-2405 213-624-0075 Fax