反对对方律师接触本方当事人
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Mr. Johnson Smith, Esq.
Baker & Barber, P.C.
620 - 5th Avenue
New York, N.Y. 10002
The United States of America
Re: China Promotion USA, Inc. v. Winston Enterprises, Inc.
Dear Mr. Smith:
It has come to my attention that you recently initiated contacts with several current
employees of my client, China Promotion USA, Inc., and have conducted telephone
interviews with them, in connection with your investigation and preparation for the
above referenced case. This was done without my knowledge or prior approval.
Your conduct in communicating with employees of my client without my consent is
highly improper and unethical, and is in violation of Rule 4.2 of the New York Rules
of Professional Conduct. See Hartford v. President and Fellows of Kate University,
N.Y. Docket No. 04-BEM-4262 (1998); Murley v. Eagle Medical Company, Inc., No.
94-11373-RBC, 1999 WL 95723 (N.Y. 1999). Moreover, I have been informed by at
least one China Promotion employee that someone from your office not only
contacted him, but also made certain false representations to him regarding the status
of litigating this case.
While I have not yet determined what action, if any, I will take regarding your
conduct, you are hereby advised to immediately cease and desist from any further
contact or communication, directly or indirectly, with any current or former employee
of China Promotion USA, Inc. without my prior knowledge and consent.
Furthermore, I request that you provide me by May 25, 2004 with a written list of the
names of all current China Promotion employees with whom members of your firm,
or anyone else on your behalf or otherwise, have had any contact regarding this
litigation (excluding the two depositions you have taken), including the dates of such
contact, the methods of such contact, and the substance of each and every
communication you or your agents have had with all such employees. Your failure
to provide me with the above information by said date will leave me with no choice
but to seek appropriate redress.
Sincerely,Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
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