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App. 4th 151, 158 (2006).) Second, a federal defendant may merely point out-near the end of the discovery stage-that the plaintiff has no evidence to support a claim. (Celotex, 477 U. Notwithstanding the foregoing, liabilities incurred before the commencement of the case shall be segregated and, in the event relief is granted, reported separately from liabilities incurred after the commencement of the case.

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