Notice of Postponement of Deposition; Motion to Quash Subpoenae or in the Alternative for a Protective Order
Public Court Documents
December 14, 1981 - December 17, 1981
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Case Files, Cromartie Hardbacks. Letter to Everett from Carraway RE Defendants’ Response to Plaintiffs’ Interrogatories, 1999. d573623b-f60e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/bc7e0eb8-b59d-46a6-8f72-493351039697/letter-to-everett-from-carraway-re-defendants-response-to-plaintiffs-interrogatories. Accessed August 19, 2025.
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State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P. O. BOX 629 REPLY TO: Frances S. Carraway. CLAS
RALEIGH Special Litigation
27602-0629 (919) 716-6900
(919) 716-6763
October 7, 1999
Robinson O. Everett VIA HAND DELIVERY
P O Box 586
Durham, NC 27702
Re: Cromartie: Defendants’ Response to Plaintiffs’ Interrogatories
Dear Mr. Everett:
Enclosed please find the declarations of Representative Edwin McMahan, Gerry Cohen and
Linwood Jones verifying the responses found in Defendants’ Response to Plaintiffs’ First Set of
Interrogatories. We hope to have Senator Roy Cooper's declaration early next week and will forward
it to you as soon as we receive it.
Sincerely,
wr
Frances S. Carraway, CLAS
Adam Stein
Todd Cox
DECLARATION
Representative W. Edwin McMahan, Chairman of the House Congressional Redistricting
Committee declares and says:
That I have read the Defendants’ Response to Plaintiffs’ First Set of Interrogatories and as
committee chairman, I am acquainted, at least generally, with the facts contained therein as they
relate to the House or me; that the response was prepared with the advice and assistance of counsel;
and that the response separately and fully answers each interrogatory, except those to which
objections are made.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the Defendants’
Response is true and correct to the best of my knowledge, information and befief.
RLS
Representative W. Edwin McMahan
DECLARATION
Gerry F. Cohen, staff counsel for the Senate Select Committee on Redistricting declares and
That I have read the Defendants” Response to Plaintiffs’ First Set of Interrogatories and as
staff counsel for the committee, I am acquainted, at least generally, with the facts contained therein
as they relate to the Senate or me; that the response was prepared with the advice and assistance of
counsel; and that the response separately and fully answers each interrogatory, except those to which
objections are made.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the Defendants’
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Response is true and correct to the best of my knowledge, information and beligf.
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Gerry F. Cohen
DECLARATION
Linwood L. Jones, staff counsel for the House Congressional Redistricting Committee
declares and says:
That I have read the Defendants’ Response to Plaintiffs’ First Set of Interrogatories and as
staff counsel for the committee, I am acquainted, at least generally, with the facts contained therein
as they relate to the House or me; that the response was prepared with the advice and assistance of
counsel; and that the response separately and fully answers each interrogatory, except those to which
objections are made.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the Defendants’
Response is true and correct to the best of my knowledge, information and belief.
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Linwood L. Jones