Summary Judgment is perhaps the most important pretrial motion. If offers the moving party an opposition to the end of litigation or to resolve significant issues in its favor.

In Anderson v. Cryovac, two summary judgments were filed. First, in May, Grace moved for summary judgment "dismissing the plaintiff's claims that they or their decedents either contracted leukemia or face an increased risk of leukemia as a result of the exposure to (TEC, Tetrachloroethylene, and 1, 2,-Trans-dichloroethylene)". Second, in February 1985, the defendants moved jointly for summary judgment on a variety of the plaintiffs' specific claims. This assignment deals with the May 1984 motion for summary judgment and the plaintiff's response.

Using the motion and the reply which you have been given, state a legal analysis in Legal Memorandum form; which answers the following questions:

1. Under Rule 56, (FRCP), the party moving for summary judgment has the burden of showing that there is no genuine issue of material fact. What did Grace present to the court to support this showing?
2. To support a claim for a negligence action, the plaintiff must present a prima facie case. How did the plaintiff respond to Grace's motion for summary judgment to overcome the defendant's argument that the plaintiff failed to prove causation?