就動(dòng)議問題和法官的直接溝通 VIA REGULAR INTERNATIONAL MAIL May 18, 2005 Superior Court of the District of Columbia Chamber of Judge Connie Claire Civil Division 500 Indiana Avenue N.W. Washington, D.C. 20001 Re: China Import & Export Corporation, Plaintiff v. Holy International, Inc., Defendant Civil Action No. 05-CA11111 Dear Judge Claire: As counsel for Defendant Holy International, Inc. in the above civil matter, I am writing to ask the Court’s assistance in moving this matter forward. This matter has been pending for some time, in part because Judge Swift dismissed the Complaint, and the Appellate Court later overturned that dismissal. By the time the matter was reassigned to you, our client had run out of funds to pay counsel due to the Asset Freeze Order. On April 1, 2005, we filed with this Court a Motion to Modify Asset Freeze Order, to allow funds to be released to pay fees and costs. The Plaintiff responded on April 5, 2005, but to this date there has been no decision from the Court. We certainly understand the Court’s busy calendar, but hope and believe that this is a relatively simple motion, which, if approved, will allow the case to go forward. We respectfully ask you to consider and act on this motion at the earliest possible date. Thank you for your time and consideration. Sincerely, Chang, Wang & Lee, P.C. _____________________ Robert M. Lee, Esq. Attorneys for Plaintiff cc: Dick B. Chitney, Esq., Attorney for Defendant
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