Letter to Everett RE: Difficulty providing requested information at Dr. Baker’s deposition

Correspondence
October 6, 1999

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Letter to Everett RE: Difficulty providing requested information at Dr. Baker’s deposition preview

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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
- 8caafde4-f20e-f011-9989-002248226c06

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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 November 23, 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

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Letter to Everett RE: Difficulty providing requested information at Dr. Baker’s deposition

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