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427 (Minn. 1988). The moving party bears the burden of showing that the material facts in the <br />case are undisputed. Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986); Mems v. City of St. Paul, <br />Dep’t of Fire & Safety Serv., 224 F.3d 735, 738 (8th Cir. 2000). <br />Material facts are those tending to establish the existence of any element essential to a <br />party’s case, and on which the party will bear the burden of proof at trial, inasmuch as the complete <br />failure of proof concerning any essential element of the non-moving party’s case renders all other <br />fact issues immaterial. See Celotex, 477 U.S. at 322-23; Carlisle v. City of Minneapolis, 437 <br />N.W.2d 712, 715 (Minn. Ct. App. 1989). If the evidence is merely colorable, or is not sufficiently <br />probative, summary judgment may be granted. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, <br />249-50 (1986). The moving party cannot rely upon mere general statements of fact, hearsay, <br />speculation or conjecture. Id. <br />Once the moving party has established a prima facie case entitling it to summary judgment, <br />the burden of proof shifts to the non-moving party. Bebo v. Delander, 632 N.W.2d 732, 737 (Minn. <br />Ct. App. 2001). The non-moving party must present specific facts showing there is a genuine issue <br />for trial. DLH, Inc. v. Russ, 566 N.W.2d 60, 70 (Minn. 1997). “The mere existence of a scintilla <br />of evidence in support of the [non-movant’s] position will be insufficient; there must be evidence <br />on which the jury could reasonably find for the [non-movant].” Anderson, 477 U.S. at 252. To <br />defeat a motion for summary judgment, the nonmoving party must submit significant probative <br />evidence; it is not sufficient to rely on general statements or simply show there is some <br />metaphysical doubt as to material facts. Carlisle, 437 N.W.2d at 715. <br />The non-moving party need not present “clear and convincing” or substantial evidence. <br />Anderson v. Minn. Dep’t of Natural Res. 693 N.W.2d 181, 191 (Minn. 2005) (stating that a genuine <br />issue of fact may have existed where each party’s expert affidavit supports an alternative <br />46