H J AMES J OHNSON

B A R R I S T E R A N D S O L I C I TO R
O F T H E F E D E R A L C O U RT S A N D T H E H I G H C O U RT O F A U S T R A L I A
w w w. j a m e s j o h n s o n 2 0 2 0 . c o m

Thursday 21 July 2010 *** IMPORTANT COMMUNICATION

Ms ### ###
Family Law Firm
666 Front Street
Capital City QLD 911

By Facsimile: 3211 4568

Dear Ms ##

FAMILY LAW PROCEEDINGS – THURSDAY ADAMS (AN INFANT), ADAM ADAMS AND HAI KON YU
1. I refer to your email messages to Mr Adams of Monday and Wednesday of this week. I also refer to Mr
Adams's facsimile to you Tuesday evening.
2. I advise that I am in the process of accepting instructions from Mr Adams to represent him for the Final
Hearing on Wednesday 27 July 2010. I will make and file the relevant notices with the Court once my
engagement is formalised. Until then, I ask that you communicate with Mr Adams as you have done up until
now. My involvement is in now way an opportunity to suggest that Mr Adams wants or might benefit from a
rescheduling of the Final Hearing next week. Quite the opposite as Mr Adams's letters and my letter to the
Court explain (see attached).
3. As to your message to Mr Adams yesterday suggesting a mention hearing tomorrow, please refer to my
facsimile today to the Court.
4. As to your message to Mr Adams of Monday I inform you on Mr Adams's behalf:
a. I expect to confirm in the next day or so that Mr Adams has retained me to represent him at the Final
Hearing starting on 27 July 2010.
b. Do you intend to rely on any of the materials prepared by either Dr Smith or Mr Jones? If so, then
please advise which materials. And, if you do, please ensure that those gentlemen are physicaly
present in Court for cross-examination. Please note that I will be challenging the admissability of the
materials prepared by Dr Smith and Mr Jones on jurisdictional grounds as well as on grounds of (lack
of) probative value and on grounds of prejudice and bias.
c. Is the document purporting to be on Dr Smith's letterhead and purporting to be dated 27 December
2009 the 'mother's psychiatric assessment' mentioned in the penultimate sentence of your message
of Monday to Mr Adams? If so, please explain what possible relevance this document has to the
issues of fact and/or law in these proceedings. I might add that in my 20 plus years of legal practice I

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 have never seen such an odd 'mother's psychiatric assessment'. Please also explain why it
apparently took some 22 days for this document to be provided to Mr Adams.
d. Please inform who your witnesses will be as a matter of urgency. And please explain why you did
not include this information in your message to Mr Adams on Monday?
e. I will inform you as to who Mr Adams's witnesses will be once I have formalised my engagement and
identified who Mr Adams's witnesses will be. I advise that Mr Adams has a long list of potential
witnesses but, in the interests of economising on scarce Court time, I will be looking to vigorously
prune that list. At this stage, Mr Adams, Mrs Adams (the paternal grandmother) and possibly Mr
Adams (the paternal uncle) will be called as witnesses. I expect I will be able to provide you with a
more complete list of Mr Adams's witnesses on Monday.
5. I refer again to my enclosed letter to the Court regarding:
a. the impropriety of any mention hearing in this matter happening tomorrow – without myself or even
Mr Adams being present given that neither of us can attend due to other pre-commitments and lack
of proper notice from the Court.
b. the impropriety of any postponement of the Final Hearing scheduled for 27 July 2010.
6. Please provide (to Mr Adams) your full and complete response to this letter no later than midday tomorrow.

Best wishes

JAMES JOHNSON

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