Letter from Everett to Stein, Smiley and Cox RE: motion to amend the Complaint

Correspondence
October 12, 1999

Cite this item

Letter from Everett to Stein, Smiley and Cox RE: motion to amend the Complaint preview

2 pages

Document text

The following text has been generated automatically during the document scanning process. It may contain errors, omissions, or incorrect formatting. Please refer to the PDF document if this text is not usable.

Download

By downloading, publishing, or reusing the Materials outside of the Website, you hereby confirm and attest that you have read and agree to the LDF Archival Collection Terms of Use linked below. We draw your attention to the following:

For those Materials owned by LDF, your use of the Material outside the Site is solely for one or more of the following (the “Permitted Purposes”):

Non-commercial research and private study;
Teaching, scholarship and instruction (including distance learning);
Non-commercial print and non-commercial online use;
Criticism, comment or news reporting; or
For people with visual disabilities (See Section 121 of the Copyright Act).
For those Materials not owned by LDF you understand that:
- It is your responsibility to determine whether the way you plan to use the materials falls within the copyright exception of Fair Use.
- For any use outside of Fair Use, it is your responsibility to seek and obtain all required permissions from any existing rights holders.

LDF hereby grants you the right to use LDF owned Materials for the Permitted Purposes without seeking further permission from LDF.

If you publish or redistribute any Materials (including excerpts and quotes), you must include a credit line and/or proper citation to the source of the Material. However, you may not use the name of LDF in any manner which creates any false association between you and LDF or that incorrectly implies any sponsorship or endorsement of you by LDF.

NOTICE: Uses that do not comply with these Terms or that do not fall under Fair Use (or another exception) may make you liable for copyright infringement.

Read the full LDF Archival Collection Terms of Use Here.

I agree to the terms and conditions for use of this content.

If you would like to use this content in other ways, contact us at .

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
- a1ccc192-ef0e-f011-9989-002248226c06

Cite this item

Case Files, Cromartie Hardbacks. Letter from Everett to Stein, Smiley and Cox RE: motion to amend the Complaint, 1999. a1ccc192-ef0e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/13eef522-fb23-4e6c-82b4-7377c5c83dec/letter-from-everett-to-stein-smiley-and-cox-re-motion-to-amend-the-complaint. Accessed December 04, 2025.

Copied!

    EVERETT & EVERETT 
ATTORNEYS AND COUNSELORS AT LAW 

  

SUITE 300 
R.O. EVERETT (1878-1971) 301 W. MAIN STREET 
KATHRINE R. EVERETT (1893-1992) 

ROBINSON O. EVERETT P.O, BOX 535 TEL: (919) 682-5691 DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 FAX: (919) 682-5469 
SANDRA G. HERRING 

  

OF COUNSEL 

ROBERT D. HOLLEMAN 

OF COUNSEL 

CRAIG M. KABATCHNICK 

(ADMITTED N.C, D.C.) 

October 12, 1999 

VIA FACSIMILE AND U.S. MAIL 

Ms. Tiare B. Smiley 

Special Deputy Attorney General 

North Carolina Department of Justice 
Post Office Box 629 

Raleigh, North Carolina 27602-0629 

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 
Washington, DC 20005 

Re: Motion to Amend the Complaint 

Dear Tiare, Adam, & Todd: 

Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, Plaintiffs request your 
written consent to amend their Complaint to conform to the evidence presented during discovery 
in regard to James Ronald Linville. Accordingly, we are sending you Plaintiff's Motion to Further 
Amend the Complaint along with the supporting memorandum. 

Please advise us as soon as possible whether you will or will not grant your written 
consent to this motion. 

 



  

Tiare Smiley 

October 12, 1999 

Page 2 

Thank you for your cooperation in this matter. 

Sincerely, 

Vi 

Ad 
obinson O. Everett 

Attorney for Plaintiffs

Copyright notice

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.

Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.

Letter from Everett to Stein, Smiley and Cox RE: motion to amend the Complaint

Impact area

Topic

Matter

Case

U.S. state

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

You may also be interested in