證據挖掘的具體時間安排
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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