和专家证人进行协调
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Professor Johnson Smith
Smith University of Science
620 - 5th Avenue
New York, N.Y. 10002
The United States of America
Dear Professor Smith:
Per your consent, I have made an appointment for you to examine and evaluate my
client, Ms. Phony Ng, who was seriously injured as a result of an industrial accident
that occurred on December 12, 2003. For all intents and purposes, it appears that
Ms. Ng, due to a shoulder injury, is permanently and totally disabled or, at least,
suffers from a significant physical impairment/disability to her right shoulder.
The appointment has been scheduled for Monday, July 4, 2004, at 2:00 p.m. By
copy of this letter to Ms. Phony Ng I am requesting that she keep this appointment,
and that she be prompt, cooperate fully, and, of course, be appropriately dressed.
Before examining Ms. Ng and rendering your examination report, please bear in mind
the following definitions of two very important evidentiary concepts. Direct
evidence is first and foremost evidence in form of testimony from a witness who
actually saw, heard or touched the subject of interrogation. As such, it is also
evidence, which if believed, proves existence of fact in issue without inference or
presumption. In contrast, circumstantial evidence is testimony not based on actual
personal knowledge or observation of the facts in controversy, but of other facts from
which deductions are drawn, showing indirectly the facts sought to be proved.
I would appreciate your examining Ms. Ng and providing me with an impairment
rating as it relates to her right shoulder.
Sincerely,
Zhang, Wang & Lee, L.L.P.
Deguang Zhang, Esq.
Enclosures
cc: Ms. Phony Ng
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