Letter to Markham from Smiley RE: Pretrial Order

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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
- c0dba293-f50e-f011-9989-002248226c06

Cite this item

Case Files, Cromartie Hardbacks. Letter to Markham from Smiley RE: Pretrial Order, 1999. c0dba293-f50e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/f8d86b08-0aec-43b7-bcb0-585e0273561d/letter-to-markham-from-smiley-re-pretrial-order. Accessed November 19, 2025.

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State of North Carolina
MICHAEL F. EASLEY Department of Justice

ATTORNEY GENERAL P. 0. BOX 629 REPLY TO: Tiare B. Smiley
RALEIGH Special Litigation

27602-0629 (919) 716-6900
FAX: (919) 716-6763

October 22, 1999

VIA FACSIMILE AND U.S. MAIL

Mr. Douglas Markham

Mr. Robinson O. Everett

Everett & Everett

Post Office Box 586

Durham, NC 27702

RE: Cromartie Pretrial Order

Dear Doug and Robinson:

Attached is our rough list of exhibits for the pretrial order. With your list in hand and the
delay of trial, we likely will be doing some revisions. We have already deleted deposition
exhibits that duplicate your designation of deposition exhibits. Our witness list has not changed,
except of course that we are adding Leslie Winner. With respect to various maps that we have
listed, the reference to “Data” is to the five basic statistical reports: deviation, total population,
VAP, registration, and elections.

We note that your lists are not formatted in a pretrial order format and do not contain a
column for objections. It would be helpful if your next version of the various lists is in the proper
format. With the delay of trial, we do not anticipate maintaining Monday’s deadline for
requesting copies of exhibits that are new or unknown to the other parties; nor do we see the need
to have the pretrial order ready by Friday. We do agree, however, that it is important to continue
to move forward in the preparation of the pretrial order and would like to come to agreement on a
revised schedule. :

Sincerely,

ice BMA
Tiare B. Smiley

Special Deputy Attorney General
cc: Adam Stein

Aodd Cox

HL. EXHIBITS

A. Deposition Exhibits

42. Shaw, et al. and Pope, et al. v. Hunt, et al. and Gingles, et al., Plaintiffs’ and

Plaintiff-Intervenors’ Motion for Leave to File an Amended Complaint Pursuant

to Rule 15(a), Fed. R. Civ. P. and Local Rule 4.00, 7/9/96

43. Shaw, et al. and Pope, et al. v. Hunt, et al. and Gingles, et al., Second Amended

Complaint for Preliminary and Permanent Injunction

44. Shaw, et al. and Pope, et al. v. Hunt, et al. and Gingles, et al., Response to Order

of June 9, 1997, 6/19/97

63. note to Robinson O. Everett, 11/29/95

B. Maps and Stipulated Data

No. Title
100. 1997 Section 5 Submission

101. 96 Congress Martin 2.0

a. Data

102. 97 Congress Cooper 2.0

a. District 1

b. District 12

Cc. Data

103. 97 Congress Cooper 3.0

a. District 1

b. District 12

C.' Data

104. 97 House/Senate Plan A

a. District ]

b.:* District 12

c.. Data

105. House 97 Congressional Plan A

a. District 1

b. District 12

C. + Datla

106. House 97 Congressional Plan A.1

a. District 1

b. District 12

c. Data

107. House 97 Congressional Plan B.1

a. District 1

b. District 12

c. Data

108. House 97 Congressional Plan E

a. District 1

b. District 12

Cc. Data

109. Comparative Maps of Districts 1 (1992 and 1997)

110.

111.

112.

113.

114.

113,

116.

117.

118.

119,

120.

121.

122.

123.

Comparative Maps of Districts 12 (1992 and 1997)
Congressional District 1 - 1992 versus 1997

Congressional District 12 - 1992 versus 1997

North Carolina Counties by Percent Population Black

with First Congressional District Overlay

Republican Victories in Forsyth County Precincts Abutting District 12

Republican Victories in Guilford County Precincts Abutting District 12

Republican Victories in Mecklenburg County Precincts Abutting District 12

Forsyth County District 12 Precincts

Guilford County District 12 Precincts

Mecklenburg County District 12 Precincts

Precinct Map (Forsyth County)

Guilford County Precinct Map

Mecklenburg County Precinct Map

Guilford County Precincts “Excluded” By Elm and Lee Streets

Plaintiffs’ Exhibits

Defendants and Defendant-Intervenors

300.

309.

310.

311.

312.

313,

314.

313.

316.

317.

318.

28 CFR §51 (1999) Appendix - to Part 51 - Jurisdictions Covered Under Section

4(b) of the Voting Rights Act, as Amended

Affidavit of Dr. Gerald R. Webster and attached report, AN EVALUATION OF

NORTH CAROLINA’S 1998 CONGRESSIONAL DISTRICTS,

Webster Tables 1 through 8

Webster Figures 1 through 12

Webster Figures A-1 through A-12

Webster Figures A-13 through A-18

ADDENDUM TO “AN EVALUATION OF NORTH CAROLINA’S 1998 CONGRESSIONAL

DISTRICTS [1997 PLAN],” Gerald R. Webster, Ph.D.

Webster Addendum Figures Al through AS

Chart: Segments Bordering the 12th District, Dr. David W. Peterson

a. Total Black Population

b. All Measures of Black Population

c. Court of Appeals Democrats

d. All Measures of Political Afiliation

Photograph of computer screen

Judgment In A Civil Case, filed 9/15/97,

Shaw v. Hunt, No. 92-202-CIV-5-BR

Order, filed 7/12/96, Shaw v. Hunt,

No. 92-202-CIV-5-BR

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Letter to Markham from Smiley RE: Pretrial Order

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