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1The non-moving party is required to designate facts which demonstrate a genuine issue for trial and must avoid conclusory allegations unsupported by factual material.2The non-moving party need only prove a material factual dispute.3All reasonable inferences must be drawn in favor of the non-moving party.
1Have summary judgment in mind from the outset of the case and throughout the case.2Keep in mind the proper timing of a motion for summary judgment.3Have a theme and a focus.4Know the rules of summary judgment.5Know the judge.
1Completely resolve a case (e.g., entry of judgment for plaintiff or defendants)2Completely resolve a claim.3Completely determine the status of a particular party.4Resolve a particular claim's application to a particular party.5Establish a fact or ruling applicable to the case as it is further adjudicated.