反對(duì)對(duì)方律師接觸本方當(dāng)事人 VIA REGULAR INTERNATIONAL MAIL May 18, 2004 Mr. Johnson Smith, Esq. Baker & Barber, P.C. 620 - 5th Avenue New York, N.Y. 10002 The United States of America Re: China Promotion USA, Inc. v. Winston Enterprises, Inc. Dear Mr. Smith: It has come to my attention that you recently initiated contacts with several current employees of my client, China Promotion USA, Inc., and have conducted telephone interviews with them, in connection with your investigation and preparation for the above referenced case. This was done without my knowledge or prior approval. Your conduct in communicating with employees of my client without my consent is highly improper and unethical, and is in violation of Rule 4.2 of the New York Rules of Professional Conduct. See Hartford v. President and Fellows of Kate University, N.Y. Docket No. 04-BEM-4262 (1998); Murley v. Eagle Medical Company, Inc., No. 94-11373-RBC, 1999 WL 95723 (N.Y. 1999). Moreover, I have been informed by at least one China Promotion employee that someone from your office not only contacted him, but also made certain false representations to him regarding the status of litigating this case. While I have not yet determined what action, if any, I will take regarding your conduct, you are hereby advised to immediately cease and desist from any further contact or communication, directly or indirectly, with any current or former employee of China Promotion USA, Inc. without my prior knowledge and consent. Furthermore, I request that you provide me by May 25, 2004 with a written list of the names of all current China Promotion employees with whom members of your firm, or anyone else on your behalf or otherwise, have had any contact regarding this litigation (excluding the two depositions you have taken), including the dates of such contact, the methods of such contact, and the substance of each and every communication you or your agents have had with all such employees. Your failure to provide me with the above information by said date will leave me with no choice but to seek appropriate redress. Sincerely,Zhang, Wang & Lee, L.L.P. Deguang Zhang, Esq.
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