Letter From Everett to Smiley RE: Interrogatories

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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
- b231284f-f90e-f011-9989-002248226c06

Cite this item

Case Files, Cromartie Hardbacks. Letter From Everett to Smiley RE: Interrogatories, 1999. b231284f-f90e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/d399dbd6-1d00-4a9e-88b6-c4162b63455a/letter-from-everett-to-smiley-re-interrogatories. Accessed November 19, 2025.

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EVERETT & EVERETT
ATTORNEYS AND COUNSELORS AT LAW

SUITE 300
R.O. EVERETT (1878-1971) 301 W. MAIN ST.
KATHERINE R. EVERETT (1893-1992) : STREET
ROBINSON O. EVERETT P.O. BOX 586
DAWN T. BATTISTE DURHAM, NORTH CAROLINA 27702

TEL: (919) 682-5691 AN 4 SANDRA G. HERRING
FAX: (919) 682-5469

OF COUNSEL

ROBERT D. HOLLEMAN September 1 1999 °

Ms. Tiare B. Smiley

Special Deputy Attorney General

North Carolina Department of Justice

Post Office Box 629

Raleigh, North Carolina 27602-0629

Re: Cromartie v. Hunt Interrogatories

Dear Tiare:

This letter is to confirm the contents of our phone conference with you and Adam

concerning the Interrogatories we served on both the State Defendants and the Defendant-

Intervenors yesterday, August 31, 1999.

In the interest of coming to a mutual agreement and avoiding any further issues about

what constitutes a “discrete part” of an interrogatory and is therefore separately counted, we are

willing to withdraw Interrogatories #8 and #10 to the Defendant-Intervenors and Interrogatories

#25, #26, #29A and #29D to the State-Defendants.

You indicated that you had some possible objections to interrogatories and we shall await

hearing from you further concerning these possible objections. If we agree that an interrogatory

is objectionable, its elimination will reduce the total. If a hearing is scheduled as to the number of

interrogatories, then these possible objections could also be considered at that time.

If our withdrawal of the above-listed interrogatories does not solve the problem, we will

attempt to arrange for a hearing before Judge Boyle or the Magistrate Judge handling this case to

discuss the interrogatories. As I mentioned, I already have left a call with David Daniel to see

about a possible hearing. Please let us know as soon as possible if a hearing will be necessary.

Sincerely,

(ls 77
Robinson O. Everett

cc. Adam Stein ¢—

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Letter From Everett to Smiley RE: Interrogatories

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