庭外当面质询通知（附带书面示证）
VIA REGISTERED INTERNATIONAL MAIL
May 18, 2006
NOTICE OF DEPOSITION OF
DEFENDANT HUABEI GROUP
TO COUNSEL FOR DEFENANT FURGUSON A. SMITH, ESQUIRE AND
CHENGPENG HU, ESQUIRE:
Counsel will please take notice that the undersigned will take the deposition of
Defendant Huabei Group, upon oral examination as follows:
Date: June 15, 2006
Time: 10:00 a.m.
Place: Law Offices of Zhang, Wang & Lee, L.L.P.
666 East Chang’an Blvd.
Beijing, P.R.China 100001
pursuant to NYCC CIVIL 111 and in the manner prescribed by the laws of the People’s
Republic of China and the State of New York. Take notice also that Defendant’s
attending the deposition is mandatory as and after Defendant has submitted to the
jurisdiction of the Court. If the deposition is not completed on the date set out
above, it will continue from day to day until completed.
You are further required to bring with you and produce the following:
a) All documents in your possession, custody, or control that evidence,
reference, or relate to any of the allegations of the Plaintiff’s Complaint and
Defendant’s Answer and Counterclaim.
b) Your corporate records including but not limited to the following:
1. Articles of Incorporation;
2. By-laws;
3. Minutes of meetings of the Board of Directors from January 1, 2000 to
present;
4. Bills of sale for the assets of Huacheng Co., Ltd.;
5. Receipts for cash payment from January 1, 2000 to present;
6. Written offers of acquisition from Holy Group or any other prospective
buyer;
7. Bank statements & cancelled checks from 2000 to present;
8. An itemized list of current investments in the United States;

9. Records of balance due on debts incurred before or after incorporation;
10. Documents relating to any contractual obligations, i.e., bank loans, any
installment credit and etc.;
11. Central and local tax returns for the years after 2000.
Respectfully submitted,
Zhang, Wang & Lee, L.L.P.
______________________
Deguang Zhang
Attorneys for Plaintiff
666 East Chang’an Blvd.
Beijing, P.R.China 100001
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing “Notice of Deposition of Defendant Huabei
Group” was mailed, first class and registered, postage duly prepaid to Ferguson A.
Smith, Esq., Attorney for Defendant, at Smith & Barney, 12345 Main Street, Suite 111,
Flushing, New York 11220, and Chengpeng Hu, Esq., Attorney for Defendant, at The
Summit Law Firm, 54321 Huiyuan Road, Suite 222, Beijing, China 100029 this 18th
day of May 2006.
______________________
Deguang Zhang
Attorneys for Plaintiff