Epstein Secrets

per acts by BoA. To the extent Mr. Steadman's claims are predicated on such acts, rather than on Green Tree's acts, they are not viable. 2 See also Johnson v. Fed Home Loan Mort. Corp.. No. C12-1712 TSZ. 2013 U.S. Dist. LEXIS 10485. 2013 WL 308957. at '4 (W.D. Wash. Jan. 25. 2013) ("IAN assignee is liab

. of L.A., 477 F.3d 652, 658 (9th Cir. 2007). The moving party bears the initial burden of showing the absence of a genuine issue of material fact. Celotex, 477 U.S. at 323. If the moving party does not bear the ultimate burden of no] persuasion at trial, it can show the absence of an issue of material

N BURNIE. MD 21061 0720 1/22/2013 13. WALTHAM, MA 02451 3/12/2004 - MIDDLESEX Boston. MA-NH - 1120 6/7/2006 14. 20070 W 151ST ST 5/1997 - JOHNSON Kansas City, MO- OLATHE, KS 66061 KS - 3760 10/24/2011 15. 17677 TORRENCE AVE 11/1998 - COOK Chicago. IL - LANSING, IL 60438 1600 1/2008

sufficient to establish the existence of an element essential to that party's case and on which that party will bear the burden of proof at trial. Celotex, 477 U.S. at 322. Moreover, "the trial court no longer has a duty to search the entire record to establish that [-22] it is bereft of a genuine iss

the existence of a Ponzi scheme and a wrongdoer's 8 EFTA00595537 Case 10-02612-RBR Doc 148-1 Filed 12/14/10 Page 9 of 10 fraudulent intent. See Johnson v. Neilson (In re Slatkin), 525 F.3d 805,811-12 (9th Cir. 2008). Further, 'criminal convictions based on operating a Ponzi scheme establish fraudule

n and identifying those portions of the pleadings, depositions, and any affidavits that demonstrate the absence of a genuine issue of material fact. Celotex, 477 U.S. at 322. The burden then shifts to the non-moving party to designate specific facts showing that there is a genuine issue of material fact