Document wk72Bnwmw7DqrXxXE58zB48Q

FEB-07-1995 12* IB FROI DRflYDEN LTfO-E & UCCD LLP l\\ 15 5-047 ^ cd TD 12129062B21-BBH300B5 P.03 CBflWWRMff JHMCH February 6, 15 SS TOi nggnmi mb.frimi w-flflitt ASB-SL^KS MS. Reginald a. tfood Drayden, wyclie a Mood* 1360 Peat Da* llvd., - St*. 1S5C Houston, Texas 7t6SS Res C.A. No. H-54-1103/ Derla Blrras, Individually and m UBgMiafetfcjet rtf fcfce Batate af fffftrrr B^Blrven. Pagsaaed, et tl y. Btaloai Caj*k ghanfteal lid Plastics Tna.p Ia tfed United state* District Court for the fieuthen District of Texas - Houston Division Dear Reggie: As wa discussed in our telephone conversation today* X am currently in trial and will toe for the next three week* to two months. This letter confirms our agreement whereby Plaintiffs will extend the time for Defendant1 a to designate their expert witnesses. Xa. turn, wa would appreciate you extending the time for Plaintiffs to respond tc Defendant's Motion for summary Judgment, very truly yours. cstrf Catharine Bssa BimmentM ceMs sinmsi fr'd UCC 073190 Turn, p.eoa AN NllSnU A31QIS Ud9T:S0 96, Z0 33J FEB-07-1995 12'19 FREPt DRRYD6N UYOC & LDDD LLP l<eS83SB5 P 04 1 BasiFTr ^ Si February 7, 1995 VTA FACSIMILE - t4*-6Zi6 fiaAwifw SAen Williams, Bailey & Wearier, ZJ ,P. S441 Gulf Freeway Suite 600 Houston, Texas 77027-5001 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" 3^ Re: Civil Action No. H 94 1 lto; Doris Erven, etaLv% Union Carbide Chemical and Plastics Company, Die.; & the United States District Court for die Southern District of Texas, Houston Division Dear Catherine: srrto&f Today, I received your lette^dated Febn&ry 6, 1995. There appon to be a slight misunderstanding that I wish to dedr tip. White I appreciate both your circumstances and your willingness to extend the timeifl which to designate Defendant's experts, simply extending the time does not solve die piobjdm. The last remains that mis case is set for trial sometime shortly after April 13, 1995, witMhe Joint pre-trial order due oAApril 7,1995. Further, discovery is cut-offon March 31,1905, We do not intend or desire Coiielay trial in this matter ip any way. Therefore, we have approximately forty-five (45) days left to complete the necessary extensive discovery. Both Ted end 1 have previously detailed to you th^acope of what must be done and the problems we arc encountering. (See Ted TheopHIos' 1 January 12,1995 and my tetters dated January 24, 1995 and February 3, 1995). Hx Therefore, we will agree to postpone the depositions of and Mazur currently set for February 12-14. (It makes littie experts and Messrs. Sdirull for Ted Theophllas to fly down here for a Sunday afternoon deposition, which probably wouldW be completed, because you would not be available on Monday).,Union Carbide will name im experts on February 20, 1995, as scheduled, but reserves the rightto name any additional experp, which nwy be required as a result of the deposition testimony and reports of your experts. ^ tx*U+l+irs* eft S'd 0**$ ^AA^mmkN WUSHU A3iais UdZT:S0 S6. Z0 S3J 161U0 JJ11 FEB-07-199S IS: 19 FRCtl DRPYDEN UYOE & LCCD LLP TO 12129062021-0203005 P.0S aw wusnw A3iais wdzi.-se sg, za a3J