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concerning summary judgment out of the 1980s. See Federal Rules of Civil Procedure 56; Celotex Corp. v. Catrett, , 322-27 (1986) (clarifying the shifting allocations of burdens of production, persuasion, and proof at summary judgment);Anderson v. Liberty Lobby, Inc., , 257 (1986) (applying heightened evidentiary standard of proof in libel action to judicial assessment of propriety of summary judgment); Matsushita Elec. Industrial Co. v. Zenith Radio Corp.,

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