Letter from Markham to opposing counsel RE Deposition of Charles Worth
Correspondence
October 11, 1999

4 pages
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Case Files, Cromartie Hardbacks. Letter from Markham to opposing counsel RE Deposition of Charles Worth, 1999. 4127cccf-f60e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/7ee7343a-e954-40ca-9f0a-5e381e00687e/letter-from-markham-to-opposing-counsel-re-deposition-of-charles-worth. Accessed July 30, 2025.
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EVERETT & EVERETT ATTORNEYS AND COUNSELORS AT LAW SUITE 300 R.0. EVERETT (1878-1971) 301 W. MAIN STREET KATHRINE R. EVERETT (1893-1992) ROBINSON O. EVERETT P.O. BOX 588 DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 TEL: (919) 682-5691 FAX: (919) 682-5469 OF COUNSEL ROBERT D. HOLLEMAN October 11, 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: Depositions of Charles J. Worth Dear Tiare, Adam, and Todd: Please have Mr. Charles J. Worth bring the following materials to his deposition on Monday, October 18, 1999. If a subpoena is necessary for Mr. Worth to comply with this request, please advise us and we will prepare the proper documents. 1. A list of all of Congresswoman Clayton’s campaign office locations for the 1992, 1994, 1996, and 1998 primary and general elections. 2. A list of all of Congresswoman Clayton’s campaign county chairmen for the 1992, 1994, 1996, and 1998 primary and general elections. 3. A list of all newspapers that Congresswoman Clayton’s campaigns have purchased political advertisements from in the 1992, 1994, 1996, and 1998 primary and general elections. Ms. Tiare Smiley October 11, 1999 Page 2 4. A list of all radio stations that Congresswoman Clayton’s campaigns have purchased political advertisements from in the 1992, 1994, 1996, and 1998 primary and general elections. 5. A list of all endorsements by names of all persons making a public endorsement of Congresswoman Clayton in the 1992, 1994, 1996, and 1998 primary and general elections. 6. A copy of all Congresswoman Clayton’s campaign literature still in existence from the 1992, 1994, 1996, and 1998 primary and general elections. 7. A copy of all direct mail that Congresswoman Clayton has sent out to over 500 persons in a single mailing in the 1992, 1994, 1996, and 1998 primary and general elections. Thank you for your cooperation in these matters. Sincerely, Dax loa & Mp ff on Douglas E. Markham Attorney for Plaintiffs EVERETT GASKINS/DURHAM TEL :919-682-5469 Oct: 11°93 EVERETT & EVERETT ATTORNEYS AND COUNSELORS AT LAW SUITE 300 R.0, EVERETT (1878-1971 : KATHRINE A, EVERETT Loa 1952) 01 WL MAN STRLEY ROBINSON O. EVERETT P.O. BOX 586 DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 OF COUNSEL ROBERT D. HOLLEMAN October 11, 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: Depositions of Charles J. Worth Dear Tiare, Adam, and Todd: Please have Mr. Charles J. Worth bring the following materials to his deposition on Monday, October 18, 1999. If a subpoena is necessary for Mr, Worth to comply with this request, please advise us and we will prepare the proper documents. 1. A list of all of Congresswoman Clayton's campaign office locations for the 1992, 1994, 1996, and 1998 primary and general elections. 2. Alist of all of Congresswoman Clayton's campaign county chairmen for the 1992, 1994, 1996, and 1998 primary and general elections. 3. Alist of all newspapers that Congresswoman Clayton's campaigns have purchased political advertisements from in the 1992, 1994, 1996, and 1998 primary and general elections. 17:22 MHo..003 P.O! TEL: (719) 682-5001 FAX: (919) 682-5489 Oct1199 17:22 No .003 P.0O2 EVERETT GASKINS/DURHAM TEL A “un Ms. Tiare Smiley October 11, 1999 Page 2 4. A list of all radio stations that Congresswoman Clayton's campaigns have purchased political advertisements from in the 1992, 1994, 1996, and 1998 primary and general elections. S. Alist of all endorsements by names of all persons making a public endorsement of Congresswoman Clayton in the 1992, 1994, 1996, and 1998 primary and general elections. 6. A copy of all Congresswoman Clayton’s campaign literature still in existence from the 1992, 1994, 1996, and 1998 primary and general elections. 7. A copy of all direct mail that Congresswoman Clayton has sent out to over S00 persons in a single mailing in the 1992, 1994, 1996, and 1998 primary and general elections. Thank you for your cooperation in these matters. Sincerely, Deargles & Maik Douglas E. Markham Attorney for Plaintiffs