證據(jù)挖掘的具體時(shí)間安排 VIA REGULAR FAX & INTERNATIONAL MAIL May 18, 2004 Mr. Johnson Smith, Esq. Barker & Barber, L.L.P. Suite 618 620 - 5th Avenue New York, N.Y. 10002 The United States of America Re: Wu Lifen v. American Pharmaceuticals, Inc. Dear Mr. Smith: This is in response to your letter of May 11, 2004 asking about the status of my discovery responses. By now you should have received plaintiff’s responses to your interrogatories and requests for production, which were mailed on May 7, 2004 and May 9, 2004, respectively. With respect to your query about scheduling the plaintiff’s deposition, I am not available in the end of May and would like to propose either June 3, 2004 or June 15, 2004 as possible alternate dates. Prior to the deposition, and in fact within the next week if possible, I would like to have copies of the documents you indicated you would produce in response to my request for production, together with copies of records that you subpoenaed from record custodians and I requested from you in my letter of April 23, 2004. Sincerely, Zhang, Wang & Lee, L.L.P. Deguang Zhang, Esq. cc: Client
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