就动议问题和法官的直接沟通
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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