Epstein Secrets

Complaint; (2) the criminal proceedings of Scott W. Rothstein and Debra Villegas;' (3) the affidavit

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

However, the Plaintiff fails to discuss meaningfully the statute at issue or provide any authority relating to the claim Plaintiff seeks to assert. (W.) E. Negligence, wantonness and breach of fiduciary duty claims against BIC (Counts VIII-XI). BIC argues that the Plaintiffs negligence, wantonness

. 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

JANET E. GRAF, TRUSTEES 166 LAFAYETTE RD OF PLUM BUSH REAL SALISBURY. MA 01952-1507 19. DAVID J. HAR

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