Letter from Markham to opposing counsel RE Deposition of Charles Worth

Correspondence
October 11, 1999

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Letter from Markham to opposing counsel RE Deposition of Charles Worth preview

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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
- 4127cccf-f60e-f011-9989-7c1e5267c7b6

Cite this item

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 November 23, 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

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Letter from Markham to opposing counsel RE Deposition of Charles Worth

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