Epstein Secrets

nt for past conduct. See, e.g., United States v. Brown, 381 U.S. 437, 456.462, 85 S.Ct. 1707, 1719-1722,

ief is sought may move, with or without supporting affidavits, for summary judgment on all or part of the claim." As stated by the Supreme Court in Celotex Corp. v. Catrett, 477 U.S. 317, 322- 323, 106 S.Ct. 2548, 2552 (1986) ... summary judgment is proper "if the pleadings, depositions, answers to interroga

a duty implied by or arising out of a contract." Brown-Marx Associates. Ltd. v. Emigrant Say. Bank, 703

udgment where the moving party demonstrates (1) the absence of a genuine issue of material fact and (2) entitlement to judgment as a matter of law. Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986); see also Galen v. Cnty. of L.A., 477 F.3d 652, 658 (9th Cir. 2007). The mo

in Shafer. In addition, Defendant has not even alleged that he would be prejudiced by the equita- ble tolling. See Baldwin County Welcome Cir. v. Brown, 466 U.S. 147, 152, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984) (discussing prejudice to the defendant as a factor the court must consider when determin

en of proof, simply point out to the Court that "the nonmoving party has failed to make a sufficient showing of an essential element of her case." Celotex Corp. v. Cat rett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed2d 265 (1986). All doubts as to the existence of a genu- ine issue of material fact must be