和專家證人進(jìn)行協(xié)調(diào) VIA REGULAR INTERNATIONAL MAIL May 18, 2004 Professor Johnson Smith Smith University of Science 620 - 5th Avenue New York, N.Y. 10002 The United States of America Dear Professor Smith: Per your consent, I have made an appointment for you to examine and evaluate my client, Ms. Phony Ng, who was seriously injured as a result of an industrial accident that occurred on December 12, 2003. For all intents and purposes, it appears that Ms. Ng, due to a shoulder injury, is permanently and totally disabled or, at least, suffers from a significant physical impairment/disability to her right shoulder. The appointment has been scheduled for Monday, July 4, 2004, at 2:00 p.m. By copy of this letter to Ms. Phony Ng I am requesting that she keep this appointment, and that she be prompt, cooperate fully, and, of course, be appropriately dressed. Before examining Ms. Ng and rendering your examination report, please bear in mind the following definitions of two very important evidentiary concepts. Direct evidence is first and foremost evidence in form of testimony from a witness who actually saw, heard or touched the subject of interrogation. As such, it is also evidence, which if believed, proves existence of fact in issue without inference or presumption. In contrast, circumstantial evidence is testimony not based on actual personal knowledge or observation of the facts in controversy, but of other facts from which deductions are drawn, showing indirectly the facts sought to be proved. I would appreciate your examining Ms. Ng and providing me with an impairment rating as it relates to her right shoulder. Sincerely, Zhang, Wang & Lee, L.L.P. Deguang Zhang, Esq. Enclosures cc: Ms. Phony Ng
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