Letter from Markham to Cox and Stein RE: Response to summary judgement and interrogatory signatures

Correspondence
November 8, 1999

Letter from Markham to Cox and Stein RE: Response to summary judgement and interrogatory signatures preview

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  • Case Files, Cromartie Hardbacks. Letter from Markham to Cox and Stein RE: Response to summary judgement and interrogatory signatures, 1999. 4214d62f-e80e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/e30c60c9-6220-4ed5-8995-38b2d276eed3/letter-from-markham-to-cox-and-stein-re-response-to-summary-judgement-and-interrogatory-signatures. Accessed June 14, 2025.

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    EVERETT & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

SUITE 300 

R.O. EVERETT (1878-1971) 301 W. MAIN STREET 
KATHRINE R. EVERETT (1893-1992) P.O. BOX 586 

ROBINSON O. EVERETT TEL: (919) 682-5691 
DAWN T. BATTISTE DurHAM, NoRrTH CAROLINA 27702 FAX: (919) 682-5469 
SANDRA G. HERRING 

OF COUNSEL 

ROBERT D. HOLLEMAN 

OF COUNSEL 

CRAIG M. KABATCHNICK 
(ADMITTED N.C., D.C.) Nov. 8, 1999 

Mr. Adam Stein 

Ferguson, Stein, Wallas, Adkins, Gresham & Sumter, PA 
Suite 2, 312 W. Franklin St., 

Chapel Hill, NC 27516 

Mr. Todd Cox 

NAACP LDEF, Inc. 

1444 Eye St., NW 10" floor 
Washington, DC 20005 

Re: Response to Summary Judgment and Interrogatory Signatures 

Dear Adam and Todd: 

Enclosed is the Plaintiffs’ Response to Defendants’ Motion for Summary Judgment, along 
with Plaintiff’s Motion for Partial Summary Judgment as to the Affirmative Defense of Claim 
Preclusion and five attachments. 

According to our files, we are still missing the signatures of the Defendant-Intervenors for 
the Plaintiff's Interrogatories to Defendant-Intervenors. We would appreciate it if you could clear 
this up as soon as possible. 

Thank you for your prompt attention to this matter. 

Sincerely, 

Dog Mobb 

Douglas E. Markham 

Attorney for Plaintiffs

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