Document 6vVe69v8OJ0bmN4NMpmJqy1m

UNITED STATES DISTRICT COURT DISTRICT OP MASSACHUSETTS CIVIL ACTION NO. 89-30201-F ALICE L. WARREN, ADMINISTRATRIX OF THE ESTATE OF JOHN H. WARREN, DECEASED, Plaintiff VS. THE DOW CHEMICAL COMPANY, THE B.F. GOODRICH COMPANY, UNION CARBIDE COMPANY and CONTINENTIAL OIL COMPANY, Defendants ) ) ) ) ) ) ) ) ) ) ) ) BRIEF IN SUPPORT OF PLAINTIFF'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE ANSWERS TO INTERROGATORIES The plaintiff states as follows in support of her motion: 1. On December 21, 1990, the plaintiff, through her attorney, received three sets of interrogatories propounded by defendants, Dow Chemical Company, Union Carbide Company and Continential Oil Com pany. The plaintiff is required under Fed. R. Civ. P., Rule 33 to furnish answers to these interrogatories within thirty (30) days or by January 22, 1991. 2. The interrogatories served on the plaintiff request a great deal of detailed information which will take a substantial amount of time to assemble. 3. The thirty (30) day extension sought will not delay these proceedings or result in any prejudice to any party. 4. Attorney Sharon R. Burger, counsel for defendants, Dow Chemical Company, Union Carbide Company and Continential Oil Com pany, has assented to the allowance of this motion. COOS'Vu