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

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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
- 35aa08aa-f70e-f011-9989-7c1e5267c7b6

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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 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

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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Letter to Everett from Smiley RE Supplement to Webster Deposition

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