詳細合作細節
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:
I have left several voice-mail messages with your office but have not heard from you.
This is to advise that plaintiff’s disclosure of experts is due on June 1, 2004, and that
our answers to interrogatories are overdue.
It is essential that we designate our experts to the defendant in advance of the above
due date. If we fail to meet our deadline, testimony from any scientists, IT expert,
music provider, or any other experts, will most likely not be admissible.
I have enclosed a copy of the pre-trial scheduling order for your ease of reference,
along with a form designation of experts from another case showing how designation
of experts is accomplished in Beijing, China.
Please prepare the expert designation and forward it to me as soon as possible,
together with Mr. Kevin Holland’s executed interrogatory answers. If there is a
problem, please call me so we can take the necessary steps to obtain an extension of
time.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
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