Letter from Markham to opposing counsel RE Deposition of Charles Worth

Correspondence
October 11, 1999

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

4 pages

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 July 16, 2025.

    Copied!

    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

Copyright notice

© NAACP Legal Defense and Educational Fund, Inc.

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.

Return to top