向客戶通報對方的和解要約
Mr. Tan Liang, President
China Trade Promotion USA, Inc.
1111 Park Avenue
New York, New York 10013
RE: China Trade Promotion, Inc. v. Jerome Hone et al.
NY Supreme Court No.: CA-04-12345
Dear Mr. Tan:
The defendant’s attorney phoned me this morning and offered USD $125,000.00 to
settle this case. From our previous discussions, I know that you are not willing to
settle for less than USD $250,000.00. However, as your counsel I am obligated to
pass this offer along to you for consideration. The offer, while less than we would
like, tells us that the defense believes that our case does have merit. I am therefore
optimistic that we may be able to negotiate a better settlement than the one offered
this morning.
As you know, the results in litigation cannot be predicted, and there is no guarantee
that we will obtain a verdict larger than this offer at trial. Even if we do, there is no
guarantee that the defendants would not appeal or that we would prevail on appeal.
Accordingly, please factor these risks involved into your decision about whether to
accept or reject this offer. My recommendation is that we respond with a
counter-demand to try to get a genuine negotiation going with the defendant.
Please give me a call to discuss this at your earliest convenience.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
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