Correspondence from Neyhart to Smiley Re: Cross Designations

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Impact area
- Criminal Justice
Topic
- Capital Punishment
LDF Attorneys
Cooperating Attorneys
Notable Person
- David Baldus
Organizations
- LDF
- Center for Interdisciplinary Legal Studies
Matter
- McCleskey v. Kemp
Case
- McCleskey v. Zant – Georgia Northern District Court (No. C81-2434A)
U.S. state
- Georgia
Collection
- Case Files
Taxonomy
Identifier
- 9a6cfec3-5aa7-ef11-8a69-6045bdd6d628

Cite this item

Case Files, Cromartie Hardbacks. Correspondence from Neyhart to Smiley Re: Cross Designations, 2000. 4f6ae9b6-e20e-f011-9989-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/c8beee7a-bddf-447e-9cfe-fbe9876d9b69/correspondence-from-neyhart-to-smiley-re-cross-designations. Accessed August 19, 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

. EVERETT AN Ce DurHAM, NORTH CAROLINA 27702 TEL: (919) 682-5691
SANDRA G. HERRING FAX: (919) 682-5469

OF COUNSEL
ROBERT D. HOLLEMAN

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

August 3, 2000

VIA FAX 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: Cross Designations

Dear Tiare:

This letter is to inform you of our final testimony cross designations. With respect to the

trial transcript, we cross designate from the testimony of Senator Cooper 391:17-392:23 and

403:1-12.

Because we still have not heard from you with regard to your basis for your assertion that

“the court admitted all Cromartie depositions in toto,” we face the dilemma of whether or not to

include our own cross-designations that were not previously designated in the PreTrial Order.

Accordingly, we are designating in the alternative.

If you are demonstrate to us an adequate basis for your understanding that all the

depositions were, in fact, admitted in toto, we have the following additional designations: Cooper

Deposition; 38:2-38:15, Weber Deposition; 33:22-34:15, 70:10-72:4, 131:8-132:15.

On the other hand, if we are correct that these depositions were not admitted in toto, we

only have the following additional designations: Cooper Deposition; 38:10-15, Weber

Deposition; 70:10-72:4.

On a final note, we were more than a little taken aback at the three hundred pages from

your office that came over our fax machine last night.

Sincerely,

SelX A. 4 i
Seth Allen Neyh

CC: Adam Stein

er Todd Cox

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Trial Proceedings Transcript Vol. 8

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