Letter from Everett to Smiley RE: Plaintiffs’ designation of witnesses
Correspondence
September 23, 1999

3 pages
Cite this item
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Case Files, Cromartie Hardbacks. Letter from Everett to Smiley RE: Plaintiffs’ designation of witnesses, 1999. f939024f-ee0e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/59a2bbcc-63e7-45e0-a3f5-9637cb68debe/letter-from-everett-to-smiley-re-plaintiffs-designation-of-witnesses. Accessed July 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 586 DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 TEL: (919) 682-5691 FAX: (919) 682-5469 OF COUNSEL ROBERT D. HOLLEMAN September 23, 1999 VIA FACSIMILE AND U.S. MAIL Ms. Tiare Smiley North Carolina Dept. Of Justice P.O. Box 629 Raleigh, NC 27602-0629 Re: Designation of Witnesses Dear Tiare: The plaintiffs hereby designate the following witnesses: 1. Dr. Ronald Weber, expert in voting behavior, redistricting standards, political science. Dr. Weber will explain how race predominates in the construction of the 1997 congressional districts, and provide information concerning crossover voting by white citizens for candidates of choice of black North Carolinians. His expert report has previously been provided to opposing counsel. 2. Mr. Lee Mortimer, an expert on local political trends and events, will explain how the splits of counties demonstrate the predominance of race. His expert report has previously been provided to opposing counsel. 4. Former State Representative John Weatherly, a member of the enacting body, will discuss legislative intent and the predominance of race as a consideration by members of the General Assembly in 1997. An affidavit was provided in the 1998 proceedings. 5. Associated Press reporter Dennis Patterson, will discuss a survey of legislators reflecting legislative intent on redistricting for the 1997 enactment. Ms. Tiare Smiley September 23, 1999 Page 2 6. Mr. Neil Williams, a former Charlotte City Council member and candidate for Congress, will discuss the racial and political climate, and the racial assignment of precincts and communities in Charlotte and Mecklenburg County. An affidavit was provided in the 1998 proceedings. 7. Mr. Martin Cromartie, plaintiff, will discuss the racial and political climate in regards to redistricting in Eastern North Carolina and Edgecombe County, and his objection to racial classification of communities. 8. Mr. Jake Froehlich, plaintiff, will discuss the racial and political climate, and racial assignment of precincts and communities in High Point, Greensboro, and Guilford County, and voter confusion from redistricting. 9. Mr. R. O. Everett, plaintiff, will discuss the racial and political climate, and racial assignment of precincts and communities in Rowan County. 10. North Carolina State Senator Hamilton Horton may be called to testify as to racial configurations of Forsyth County in the 12™ District. (He is presently out of the country until October 7, 1999) 11. North Carolina State Representative Steve Wood may be called to testify as to racial configurations of High Point in the 12" District. The plaintiffs also reserve the right to use portions of prior testimony or sworn statements, or to call as adverse witnesses Mr. Gerry Cohen, Sen. Roy Cooper, Rep. Ed McMahan, Sen. Leslie Winner, Mr. Gary Bartlett, and Mr. Linwood Jones. In the event that details of the chronology of redistricting in the 1990s, technical details of precinct structure, assignment and division, and redistricting computer operation and data cannot be stipulated, plaintiffs would in such an instance call either Mr. William Gilkerson, Mr. Dan Frey of the Information Systems office, or the respective county election official. In the event that matters relating to MDA designations and meaning cannot be stipulated, the plaintiffs plan to call an attorney knowledgeable regarding FCC matters, or an owner or operator of a media station. Ms. Tiare Smiley September 23, 1999 Page 3 cc: Adam Stein eC. Tod Cox Sincerely yours, by: Jet A. Toyo t Robinson O. Everett