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

Correspondence
October 12, 1999

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

2 pages

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  • 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 June 13, 2025.

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    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

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