NORTH CAROLINA GENERAL ASSEMBLY

NORTH CAROLINA SENATE

April 23, 2020

Governor Roy Cooper Secretary Mandy Cohen

20301 Mail Services Center 101 Blair Drive
Raleigh, NC 27699 Raleigh, NC 27603

VIA ELECTRONIC DELIVERY

Dear Governor Cooper and Secretary Cohen:

Pursuant to our authority under G.S. 120-19, we request immediate production of materials
related to our informal inquiry via letter dated April 15, 2020.

Your administration’s executive orders have impacted every one of this state’s 10 million
residents. As a basis for the restrictions you have put in place, your orders explicitly cite the
modeling developed with academic collaborators under the direction of the N.C. Department
of Health and Human Services (DHHS). The data and assumptions underlying those models
are therefore of exceptional public interest and import.

Yet you have declined to answer basic questions about your modeling. On April 15, we asked
your administration to “make available their estimated number of hospitalizations” from the
modeling released by DHHS. We also requested that your administration “make the
underlying model and data available to us.”

North Carolina law requires you, upon request of “any individual member of the General
Assembly,” to provide “all information and all data within [your] possession, or ascertainable
from [your] records.”

Pursuant to North Carolina law, we request:

• All data associated with the model released by DHHS on April 6, 2020, including
precise projected COVID-19 hospitalizations and hospital capacities;
• All assumptions used to create the model released by DHHS on April 6, 2020,
including assumptions used to create the underlying models on which DHHS based
its model;
• All records associated with the model’s development, including all correspondence
within DHHS and all correspondence between DHHS and outside researchers.
Transparency, not secrecy, will foster public trust during a pandemic. Please respond with
the underlying model data, which is certainly available and obtainable, by tomorrow, April
24. Please provide the other requested materials on a rolling basis as they become available.

Sincerely,

Senator Joyce Krawiec Senator Jim Burgin Senator Ralph Hise