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.S.C. § 1983 for: (1) a substantive due process violation based on arbitrary enforcement of the tax laws; and (2) a procedural due process violation based on inadequate notice of a tax collection proceeding. Defendants then filed a motion for summary judgment. In the motion, defendants argued that (1) plaintiffs could not maintain an action for arbitrary enforcement; and (2) plaintiff failed to meet its burden of proof as to both procedural and substantive due process violations. In response, plaintiffs' counsel informed the Court that plaintiffs had no objection to the defendants' motion. The Court granted plaintiffs thirty days in which to file a response to the defendants' motion. Plaintiffs did not file any response to the motion. Discussion Under Fed.R.Civ.P. 56(c), summary judgment shall be granted if the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Fed.R.Civ.P. 56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 265 (1986). In determining whether a genuine issue of material fact exists, the evidence is to be taken in the light most favorable to the non-moving party. Perini Corp. v. Perini Construction, Inc., 915 F.2d 121, 123-24 (4th Cir.1990). Summary judgment is not appropriate where there is an issue of fact for trial. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 2510, 91 L.Ed.2d 202 (1986). A fact is material for purposes of summary judgment, if when applied to the substantive law, it affects the outcome of the litigation. Id. at 248, 106 S.Ct. at 2510. Summary judgment is warranted when the party bearing the burden of proof at trial does not establish an essential element of his case. Id. at 252, 106 S.Ct. at 2512. Plaintiffs bear the burden of proving that defendants violated plaintiffs' constitutional rights. See Santos v. Franklin County Dist. Bd. of Elections, 559 F.Supp. 1554, 15




Horizon Zero Dawn: The Frozen Wilds Tamil Dubbed Movie Torrent

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