和當(dāng)事人就專家證人問題進行溝通
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Mr. Johnson Smith
Providence Group, Inc.
620 - 5th Avenue
New York, N.Y. 10002
The United States of America
Dear Mr. Smith:
Please allow this to serve as a status report on your case.
I have met with our expert, professor Xu Lu of Nanjing University School of Law,
who has reviewed your matter in detail. He has agreed to and will testify on your
behalf that defendant committed legal malpractice, which caused economic injury to
you. In Professor Xu’s opinion, the legal malpractice consists of failure of your
attorney to use such skill, prudence, and diligence as lawyers of ordinary skill and
capacity commonly possess and exercise in performing tasks that they undertake.
When such failure proximately causes such damages as you have suffered, it gives
rise to an action in tort. A letter from professor Xu is enclosed for your records,
together with a copy of his bill so far, which I have paid out of the retainer you sent
me.
I am enclosing a listing of the monies you have paid me and the monies I have spent
on your case so far. You have a positive balance of USD $1,167.68. This amount
of money will be spent on professor Xu and the photocopies of defendant’s file.
You will see from professor Xu’s letter that he expects to spend more time on this
matter, and I may therefore be needing additional money from you in the future.
Please bear this in mind for purposes of your financial planning.
I will continue to keep you informed of developments in your case, but please call me
if you have any questions.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
Enclosures
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