Letter to Smiley from Everett RE: Winner Deposition

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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
- 004f4f06-e90e-f011-9989-7c1e5267c7b6

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Case Files, Cromartie Hardbacks. Letter to Smiley from Everett RE: Winner Deposition, 1999. 004f4f06-e90e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/9169d3e9-625c-4df2-9bcc-ce8eaa104969/letter-to-smiley-from-everett-re-winner-deposition. Accessed December 04, 2025.

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Eh 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 TEL: (919) 682-5691
DAWN T. BATTISTE DurHAM, NORTH CAROLINA 27702 FAX: (919) 682-5469
SANDRA G. HERRING

OF COUNSEL
ROBERT D. HOLLEMAN

OF COUNSEL
CRAIG M. KABATCHNICK
(ADMITTED N.C., D.C.)

October 12, 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

Re: Winner Deposition

Dear Tiare:

Let me respond to your letter of October 11 in regard to the deposition of Ms. Winner.

(1). We appreciate your fixing the 10:00 P.M. deposition time for Ms. Winner’s

deposition. This eliminates the need for heroic measures on our part to brave the rush hour traffic
and arrive earlier.

(2). We shall accept Ms. Winner’s offer and will have that offer and acceptance noted at

the beginning of the deposition in order to avoid any confusion or misunderstanding.

(3). We appreciate Ms. Winner's efforts to locate material responsive to our request, and
we shall await the results.

(4). With regard to the erroneous references to “Frank Church”, Charles J. Worth is the

intended deponent. All statements referring to Frank Church should be read to indicate Mr.
Worth. To clear up any confusion in this regard, a separate letter has been sent regarding the

materials which we are requesting Mr. Worth to bring to his deposition.

Tiare Smiley

October 12, 1999

Page 2

Sincerely,

Robinson O. Everett

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Letter to Smiley from Everett RE: Winner Deposition

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