两大诉讼模式的相互借鉴是当今世界程序制度改革共同探讨的话题,然而诉讼模式更多的是一种文化沉淀的产物,这一点在我国探讨引进美国对抗制的各种论说中似乎大大地被忽略了。约翰·莱兹(John C.Reitz)从相反的角度分析了两大诉讼模式融合的设想在特定的法律文化中可能面临和产生的问题,这种思路将给我们一个很好的启示。 The mutual reference of the two major litigation models is a topic that is discussed jointly in the reform of the procedural system in the world today. However, the mode of litigation is more of a product of cultural deposition, which appears to have been greatly overshadowed in our various discussions on the introduction of the U.S. antagonistic system Ignored. On the contrary, John C. Reitz analyzes the possible problems confronting and arising from the assumption of the two legal models in a particular legal culture. This kind of thinking will give us a very good inspiration.