Letter to Everett From Smiley RE: Confirmation of Schedule For Depositions

Correspondence
August 30, 1999

Letter to Everett From Smiley RE: Confirmation of Schedule For Depositions preview

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  • Case Files, Cromartie Hardbacks. Letter to Everett From Smiley RE: Confirmation of Schedule For Depositions, 1999. e5f01e8d-e80e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/a7c66a09-8ed5-43d2-a03c-e541670613be/letter-to-everett-from-smiley-re-confirmation-of-schedule-for-depositions. Accessed June 03, 2025.

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    MICHAEL F. EASLEY Department of Justice 

ATTORNEY GENERAL P.O. BOX 629 REPLY TO: Tiare B. Smiley 
RALEIGH Special Litigation 

27602-0629 (919) 716-6900 

(919) 716-6763 

August 30, 1999 

Mr. Robinson O. Everett 

Everett & Everett 

Post Office Box 586 

Durham, NC 27702 

Re: Cromartie Depositions 

Dear Robinson; 

This letter is to confirm that plaintiffs will take the deposition of Senator Roy Cooper on 

Thursday, September 9, 1999, at 1:30 p.m. and Dr. David Peterson on Monday, September 20, 1999, 

at 11:30 a.m., in Room 301, Old Education Building, 114 W. Edenton Street, Raleigh, North 

Carolina. In addition, Representative Ed McMahan can be available in Raleigh at the same location 

on Friday, October 1, 1999, anytime after 8:30 a.m. Based on Representative McMahan’s schedule, 

it would be very difficult to schedule his deposition any earlier, so please let us know if this works 

for you. Also, please let Kay McGovern know about the dates, times and locations for these 

depositions. 

We understand that Dr. Weber cannot be available for a deposition on the day following 

Dr. Peterson’s deposition. Please let us know when he can be available. The following is our current 

list of other persons we will want to schedule for depositions: Martin Cromartie, Thomas Chandler 

Muse, Robert Weaver, Joel K. Bourne, R. O. Everett, J. F. Froelich, Jr., James Ronald Linville and 

Susan Hardaway. We do not anticipate that these depositions of named plaintiffs will take 

very long and three or four can be scheduled back to back on the same day. If you intend to call  



  

Mr. Robinson O. Everett 

August 30, 1999 

Page 2 

Neil C. Williams, John Weatherly or Lee Mortimer as witnesses, we will want to schedule deposition 

dates for them too. Let me know who plaintiffs want to depose and we can attempt to work out a 

preliminary deposition schedule. 

Sincerely, 

Tiare B. Smiley 

Special Deputy Attorney General 

TBS/fa 

CC: Senator Roy Cooper 

Representative Ed McMahan 

Dr. David Peterson 

dam Stein 

odd Cox

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