強迫對方提供證據(jù)
VIA CERTIFIED MAIL
May 18, 2006
Aima A. Torney, Esquire
111 Cockroach Blvd.
Anytown, SD 80113
U.S.A.
Re: Mrs. Battery Wang v. U.S. Border Partrol
US District Court: CA No. 04-11111
Dear Ms. Torney:
With reference to the above captioned matter, I would appreciate it if you would
immediately address your client’s outstanding discovery responses. Interrogatories
and a Request for Production of Documents were forwarded to your attention on or
about March 15, 2006.
On April 1, 2006, we agreed that you would not have to respond to my Discovery
Requests until the court ruled on your Motion for Reconsideration. As you are
aware, that Motion was denied by Judge Oukei on April 7, 2006.
I also had contacted you on two separate occasions in regard to this Discovery, once
on or about April 19, 2006, and again on or about April 30, 2006. Both times you
assured me that responses were forthcoming but none has been received so far.
Given the above and as our discovery deadline is fast approaching, I am left with no
other choices but to warn you that if I shall not receive your responses to my
discovery requests by the deadline I will be forced to file a motion with the court to
compel and for sanctions if appropriate. Please call me as soon as possible so we
may avoid any unnecessary delays and unpleasantness in resolving this case.
Sincerely yours,
Zhang, Wang & Lee
_________________
Deguang Zhang, Esq.
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