Letter to Smiley from Everett and Neyhart RE: Expert witnesses

Correspondence
September 24, 1999

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Letter to Smiley from Everett and Neyhart RE: Expert witnesses 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
- 66200667-ef0e-f011-9989-7c1e5267c7b6

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Case Files, Cromartie Hardbacks. Letter to Smiley from Everett and Neyhart RE: Expert witnesses, 1999. 66200667-ef0e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/8fe03b3e-7491-4454-adae-ad8be9525d6b/letter-to-smiley-from-everett-and-neyhart-re-expert-witnesses. Accessed November 23, 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) P.O. BOX 586
ROBINSON O. EVERETT
DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 TEL: (919) 682-5691

FAX: (919) 682-5469

OF COUNSEL
ROBERT D. HOLLEMAN

September 24, 1999

Ms. Tiare B. Smiley

Special Deputy Attorney General

North Carolina Department of Justice
Post Office Box 629

Raleigh, North Carolina 27602-0629

Re: Cromartie v. Hunt Expert Witnesses

Dear Tiare:

This letter is to confirm our conversation this afternoon concerning two of your listed

expert witnesses. My understanding from our conversation is that you have withdrawn Dr.

Goldfield and Dr. Stuart from your list of expert witnesses. Accordingly, they will not be called

as witnesses at the upcoming trial, nor will their reports be filed with the court.

If this is indeed the case, we of course will no longer seek to depose either Dr. Goldfield

and Dr. Stuart. Please let us know as soon as possible if our understanding is incorrect.

In addition, we also look forward to hearing from you Monday morning concerning the

availability of Leslie Winner. We can depose her in Raleigh or in Charlotte. Likewise, we can

depose Rep. Watt’s staff member in Washington D.C., Raleigh, Charlotte, or some other city of

the 12™ District. We assume that you can arrange for Rep. Clayton’s assistant to be present for a

deposition in D.C. or Raleigh.

9:00 A.M. September 30 in Washington D.C. would work for us as I have to go to

Washington that day, but obviously Raleigh would be our preference. We shall check with the

three Tarboro plaintiffs who have not been deposed to see how October 4 or October 6 would

work for them.

Sincerely,

Rebirmen. 0. Graal

bys dt a. 7X

Robinson O. Everett

cc. Adam Stein

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Letter to Smiley from Everett and Neyhart RE: Expert witnesses

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