Letter to Everett from Smiley RE Supplement to Webster Deposition

Correspondence
October 22, 1999

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Letter to Everett from Smiley RE Supplement to Webster Deposition preview

2 pages

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  • Case Files, Cromartie Hardbacks. Letter to Everett from Smiley RE Supplement to Webster Deposition, 1999. 35aa08aa-f70e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ea7748f5-8cc4-4803-9eac-e5a0581a6e58/letter-to-everett-from-smiley-re-supplement-to-webster-deposition. Accessed June 14, 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 

919) 716-6900 27602-0629 ( 
ry 2 FAX: (919) 716-6763 

October 22, 1999 

Mr. Robinson O. Everett 

Everett & Everett 

Post Office Box 586 

Durham, NC 27702 

Re: Supplement to Webster Deposition 

Dear Robinson: 

When Dr. Webster reviewed his deposition for corrections, he found the following three 
matters that needed further comment: 

1. Page 5-6. Mr. Popper asked if I'd been hired as a consultant for cases in which I did not 
testify at trial. The Baldwin County commission case should be added to my response. At this point 
it has not gone to trial 

2. Page 28. Mr. Popper asked if I'd given donations to political candidates. After my 
deposition] remembered I'd attended a campus gathering for Democrat Don Siegelman which was 
hosted by the Higher Education Partnership (HEP). The HEP held multiple such receptions in 
advance of the 1998 gubernatorial election for both Republicans and Democrats. 1 gave Mr. 
Siegelman a donation at his reception. To the best of my recollection the donation was for $25. 

3. Page 75. Mr. Popper asked if I'd read the decision by the three judge panel granting 
summary judgment. I do not recall having read it but I did recall that some of my coefficients were 
used in the decision. I do not know if I remember this because I read it or was told that my 
coefficients were used. In short, rather than respond “I am almost sure I haven’t”’I should likely have 
responded “I don’t remember having read it.” After having given it a lot of thought, there would have 
been no direct reason for me to have spent time reading it other than my own curiosity. 

 



    

Mr. Robinson O. Everett 

October 22, 1999 

Page 2 

  

The signature page and correction sheet have been forwarded to the court reporter who will 
distribute them in due course. 

Sincerely, 

tie Kw 
Tiare B. Smiley 

Special Deputy Attorney General 

  

TBS/fa 

CC: Adam Stein 

Todd Cox

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