Letter to Smiley from Neyhart RE: Alteration of Peterson maps

Correspondence
November 17, 1999

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Letter to Smiley from Neyhart RE: Alteration of Peterson maps 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
- 832c12c2-d90e-f011-9989-7c1e5267c7b6

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Case Files, Cromartie Hardbacks. Letter to Smiley from Neyhart RE: Alteration of Peterson maps, 1999. 832c12c2-d90e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/b41e189a-ae6c-41b3-87dd-04458698dad2/letter-to-smiley-from-neyhart-re-alteration-of-peterson-maps. 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. EVER - ETT (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 November 17, 1999

OF COUNSEL
CRAIG M. KABATCHNICK

(ADMITTED N.C., D.C.)

Ms. Tiare Smiley Via Fax to 716-6763

North Carolina Dept. of Justice

P. O. Box 629

Raleigh, NC 27602-0629

Re: Alteration of Peterson Maps

Dear Tiare:

While reviewing Defendants’ Exhibit 430 this afternoon, I noticed that it was significantly

different than the map for Rowan County which Mr. Markham had previously examined in Dr.

Peterson’s office. Specifically, the handwritten numbers were removed and were replaced with

typewritten numbers. Also, the question marks on the map which Mr. Markham had observed

were removed.

When I brought this to the attention of Fran Carraway, she informed me that Dr.

Peterson’s staff had done this contrary to her specific instructions. She also informed me that

some or all of the question marks had been erased on the other Peterson maps and had been
replaced by numbers.

As you know, Mr. Markham examined the original maps in their original state for the

purposes of a potential cross-examination of Dr. Peterson. Furthermore, he has specifically

expressed his concern to you that the original markings be preserved on these maps.

We are deeply concerned that the evidentiary value and authenticity of these maps have

been compromised. At this point, we see no alternative but to request that all changes in these

maps be enumerated and a reason be given for each of the changes.

Thank you for your attention to this matter.

Sincerely,

debh A. Flesh
Seth A. Neyhart

Attorney For Plaintiffs

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Letter to Smiley from Neyhart RE: Alteration of Peterson maps

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