A. SmMITHMOORE SZ LEATHERWOOD April 22, 2009 Ms. Toni Michelle Jackson Senior Trial Attomey United States Department of Justice Civil Rights Division, Employment Litigation Section 950 Pennsylvania Avenue, NW, PHB 4027 Washington, DC 20530 Re: Lawrence Alexander, Jr, etal. v, City of Greensboro, Dear Ms. Jackson: ‘This letter isin response to your correspondence dated April 15, 2009. With respect to your request for Internal Affairs files, I indicated that the City would be willing to notify the charging parties of your request and, if they agreed in writing to release their Internal Affairs files to you, the City would provide you with those files. Consistent with this representation, the City is in the process of notifying each of the charging parties of your request and determining whether it has the appropriate consents to provide you with the files. I will keep you apprised. You have requested that the City arrange for you to speak with 26 individuals, both present and former employees, during the 4 day period April 28 - May 1. Some of the individuals identified are represented by counsel. We have forwarded your request accordingly, as follows: Seth Cohen ~ 336-274-2992 Seth Cohen ~ 336-274-2992 Seth Cohen ~ 336-274-2992 ‘iscet 363785256 | Fe 386435 7478 | julie theal@rmihrooelwe com Smith Moore Destherwood LLP «© Anoraeys at Law PO foc 21997 (7420) BHO North Cece Seek Suite 1400 Greensbore, NC 27401 + 3363785200* sew sithmoncaw com an, eansbore, NC * Grou, SC *alagh, NC * Wilmington, NC vote, NCMs. Toni Jackson April 22, 2009 Page 2 Seth Cohen ~ 336-274-2992 Ken Keller ~336-379-8651 Gray Wilson ~ 336-631-8866 With respect to the remaining 20 individuals, the City does not consent to interviews of current or former supervisory personnel outside the presence of the City’s counsel or on the time table that you propose. Aside from the logistical difficulties of arranging this many interviews oon short notice, the City has already spent many hours and incurred much legal expense voluntarily providing information with no indication from the Department of Justice about what, if anything, remains a concern. For much of the past twenty years — and currently - the Police Department of the City of Greensboro has been privileged to be led by respected chiefS who happened to be Affican American, ‘The circumstances surrounding the In short, and respectfully, it is difficult to determine what goal is being accomplished by spending the City’s revenue, most of which comes from its taxpayers, on continued efforts to investigate a matter that, for all practical purposes; has been resolved. Please call one of us at your convenience to discuss narrowing the list of individuals you wish to interview as well as an appropriate procedure. With kindest personel regards, Lam Sincerely, Sie ©. Theat (by Aad) Julie C. Theall Wan WD) andor Alan W. Duncan,