Letter to Everett From Smiley RE: Confirmation of Schedule For Depositions
Correspondence
August 30, 1999
2 pages
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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 November 19, 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