會后確認協商內容
ZHANG, WANG & LEE, L.L.P.
ATTORNEYS AND COUNSELLORS AT LAW
666 EAST CHANGAN BOULEVARD
BEIJING, P.R. CHINA 100001
TELEPHONE: 010-1234-5678; TELEFAX: 010-1234-5679
WWW..ZWL.COM.CN
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Mr. Johnson Smith, Representative
Providence Group, Inc.
Suite 618
620 - 5th Avenue
Beijing, China 100012
Dear Mr. Smith:
Thank you for taking the time to meet with us yesterday to discuss the progress on
your case. At the outset, I must say I thought the meeting was very productive for all
of us. Here, I would like to go over the major issues that we discussed and the
decisions we made yesterday.
First, you have authorized us to engage the services of an outside counsel to assist in
this matter. As we discussed yesterday, there will be no direct cost to you for these
services. It is our intention to enter into a written agreement wherein the outside
counsel will receive a portion of the attorneys’ fees due to this firm in the event that
we prevail on the case. Additionally, it is my intention to seek contribution from the
outside counsel for ongoing expenses in an amount proportionate to our fee agreement
with them.
You also authorized us to retain the services of a second expert witness. As you
know, this expert has requested a RMB 8,000.00 (USD $1,000.00) retainer, and it is
my intention to engage his services in the very near future.
We also discussed a budget for expenses in this case. At the present time, my
prediction is that total expenses could very well be in the range of RMB 200,000.00
(USD $25,000.00) if we have to complete formal discovery and prepare for trial.
You were kind enough to agree to pay 100% of all of the expenses thus incurred.
Finally, following a discussion of the pros and cons of mediation and arbitration, you
have authorized us to attempt to arrange a non-binding mediation with the defendant.
As we discussed, I anticipate that our share of the expenses for the mediation would
be RMB 4,000.00 (USD $500.00). I will attempt to make the necessary
arrangements as soon as possible.
I hope that this letter accurately reflects the decisions we made yesterday. If not, I
would be most appreciative if you could let me know at your earliest convenience.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
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