[brief] See *Brill v. Guardian Life Ins. Co.*, 142 N.J. 520, 528-29 (1995).  Summary judgment is designed to protect parties against the expense of protracted litigation where a trial would serve no useful purpose.  *Kopp Inc. v. United Technologies, Inc.*, 223 N.J. Super. 548, 555 (App. Div. 1988).  Summary judgment should only be granted when a search of the documents submitted clearly shows there is no “genuine issue of material fact requiring disposition at trial. ”  *Judson v. Peoples Bank & Trust of Westfield*, 17 N.J. 67, 74 (1954).  The standard in New Jersey is substantively controlled by the summary judgment standard proffered by the New Jersey Supreme Court in *Brill v. Guardian Life Insr. Co. Of America*, 142 N.J. 520, (1995) pursuant to R. 4:46-2.  Under this standard, once the movant demonstrates there is no genuine issue of material fact, the burden then shifts to the non-movant to “establish the existence of a genuine issue of material fact. ”  Heljon Management Corp. v. DiLeo, 55 N.J. Super. 306, 313 (App. Div. 1959).  Failure to discharge this duty entitles the movant to summary judgment.  Id.  Mere conclusory denials are insufficient to defeat a plaintiff’s motion for summary judgment, unless the denials are supported by factual statements and evidence.  Pipe & Foundry Co. v. American Arbitration, 67 N.J. Super. 384 (App. Div. 1961).  “[W]hen the evidence is so one-sided that one party must prevail as a matter of law, the trial court should not hesitate to grant summary judgment. ”  Brill, 142 N.J. at 540.  The essential inquiry is “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law. ”  Id. at 536; Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986).  In determining whether a genuine issue of fact exists, it is well settled that although “allegations of the pleadings standing alone may raise an issue of fact, if other papers show that there is no material issue,” then summary judgment should be granted.  Campbell v. New Jersey Auto Ins., 270 N.J. Super. 379, 384 (App. Div. 1994).  In sum, “[i]f the opposing party in a summary judgment motion offers only facts which are immaterial or of an insubstantial nature, a mere scintilla, fanciful, frivolous, gauzy, or merely suspicious, he will not be heard to complain if the court grants summary judgment.  *Brill*, 142 N.J. at 529 (internal citations and quotations omitted).  “New Jersey does not follow the scintilla of evidence rule. ”  *Golddome Realty Credit Corp. v. Hardwick*, 236 N.J. Super. 118, 124 (Ch. Div. 1989) (internal citations and quotations omitted).  Thus, even “if there exists a single, unavoidable resolution of the alleged disputed fact, that issue should be considered insufficient to constitute a genuine issue of material fact for purposes of R. 4:46-2. ”  *Brill*, 142 N.J. at 540 (internal citations and quotations omitted).  “[P]rotection is to be afforded against groundless claims and frivolous defenses, not only to save antagonists the expense of protracted litigation but also to reserve judicial manpower and facilities to cases which meritoriously command attention. ”  *Id.*, at 542.  LEGAL ARGUMENT I.