Fax from Markham to Smiley RE: response to proposed stipulations

Correspondence
November 23, 1999

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Fax from Markham to Smiley RE: response to proposed stipulations 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
- 24401f2e-e00e-f011-9989-002248226c06

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Case Files, Cromartie Hardbacks. Fax from Markham to Smiley RE: response to proposed stipulations, 1999. 24401f2e-e00e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/dfb5dc1d-56e6-41ca-b233-517eb5fad246/fax-from-markham-to-smiley-re-response-to-proposed-stipulations. Accessed November 19, 2025.

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    EVERETT GASKINS/DURHAM ao = Noy 23.9% 20:47 No .023'P.0l 

EveEretT & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

SUITE 300 
R.O. EVERETT (1878-1971) 301 W. MAIN STREET 
KATHRINE A. EVERETT (1898-1002) P.O. BOX 586 
ROBINSON O, EVERETT TEL: (919) 882-8601 
DAWN T. BATTISTE DurHaMm, NorrH Carolina 27702 FAX: (919) 882-5469 

SANDRA G. HERRING 

  November 23, 1999 
QF COUNSEL 

ROBERT D. HOLLEMAN 8 p.m. 
OF COUNBEL 

CRAIG M. KABATCHNICK 
(ADMITTED N.C., D.C.) 

Ms. Tiare Smiley Via Fax to 716-6763 

North Carolina Dept. of Justice 

P. O. Box 629 
Raleigh, NC 27602-0629 

re TIN 

We have received your proposed stipulations about an hour ago. We cannot agree to 5, 7, or 8, 

because they are untrue. We cannot agree to 16 or 18 because each is misleading. 

Dear Tiare: 

We can agree to 1, 2, 3,4, 9, and 19. 

With corrections or additions to reflect “context” we can agree to 6, 13, 14, 15, 17. 

With wording changes we could agree to 10, 11, 12, and 13. 

Here are our proposals: 

4 While the 1982 Plan divided four counties and the 1992 Plan divided 44 counties, the 1997 

Plan divides 22 counties. Six of these are in the 12" District and 10 are in the First District. 
( 

jo A 0 or . , ' , [por 

We , District 1 of the 1997 plan is technically contiguous. 
; : Ww 

ro / NPA 
. . » + [] : 5 ¢ 

. District 12 of the 1997 plan is technically contiguous. ( pram Ry he 

HY >12. The 1997 Plan does not have “point contiguity”, “cross-overs”, or “double cross-overs”. £ pert” 
{ 

13. District 12's African-American total population was reduced from 56.63 percent in the 1992 

Plan to 46.67% in the 1997 Plan and 35.58% in the 1998 Plan. 

  

   

    

   

  

j Fa in the 1992 plan to 43.36 percent in the 1997 Plan and 32.56% in the 1998 Plan. 

5 . The dispersion compactness score of District 12 was 0.045 in the 1992 Plan and 0.109 in the 

1997 Plan, North Carolina’s congressional districts in the 1982 Plan had an average dispersion 

score of .36, a low of .26 and a high of .57. 

 



    

  

EVERETT GASKINS/DURHAM TEL :919-682-5469 Now. 23799 20:48 No .023P.02 

Ms. Tiare Smiley 
November 23, 1999 

Page Two 

LN measured by their dispersion and perimeter scores, the levels of compactness for North 

Carolina's twelve congressional districts increased in the 1997 Plan as compared to the 1992 Plan, 

but remains lower as compared to the 1982 Plan, 

oS i 

\%% ef ohn ox Yours Very Truly, 

Wahi fs L . of pr os 
AK CE Douglas E. Markham 

ce: Mr. Adam Stein, via fax to 967-4953 

Mr, Todd Cox, via fax to 202-682-1312

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Fax from Markham to Smiley RE: response to proposed stipulations

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