要求對方迅速合作完成證據(jù)發(fā)掘工作
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Mr. Johnson Smith, Esq.
Smith & Cheney, L.L.P.
Suite 618
620 - 5th Avenue
New York, N.Y. 10002
The United States of America
Re: American Records, Inc. v. Huaguang CDs Co., Ltd.
Dear Mr. Smith:
This is just a reminder that I have not received the discovery requests that you want
me to propound to the defendants. You stated in your letter of May 2, 2004 that you
would e-mail the requests to me.
Discovery as practiced in the U.S. is not a standard pre-trial procedure commonly
employed in China. Not only do I need to educate the adverse counsel in order to
get him involved, but I also need to translate your requests into workable Chinese
legal language. Since defendants will have 30 days to respond to the discovery and
15 days to respond to any motion to compel, you can see that we are running out of
time to comply with the court order requiring all discovery to be completed, and all
discovery disputes to be resolved, by June 25, 2004.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
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