[brief] In opposing [...]’s summary judgment motion, Plaintiff failed to produce any evidence of negligence on [...]’s part that proximately caused his alleged injuries.  It is fundamental that “negligence must be proved and will never be presumed, that indeed there is a presumption against it, and that the burden of proving negligence is on the plaintiff.  Buckelew v. Grossbard, 87 N.J. 512, 525 (1981), citing Hansen v. Eagle-Picher Lead Co., 8 N.J. 133, 139 (1951).  The plaintiff bears not only the burden of proving the defendant’s negligence, but also “that such negligence was a proximate cause of plaintiff’s injury. ”  Dziedzic v. St. John’s Cleaners and Shirt Launderers, Inc., 53 N.J. 157, 161 (1969).  In order to establish a cause of action for negligence, a plaintiff must establish that (1) defendant owed a duty of care to the plaintiff; (2) defendant breached that duty; (3) proximate cause; and (4) actual damages.  Townsend v. Pierre, 221 N.J. 36, 51 (2015).  In Germann v. Matriss, 55 N.J. 193, 205 (1970), the court expanded the proof of negligence to include evidence or reasonable inferences therefrom showing a proximate causal relation between the defendant’s negligence and the resulting injury.  However, the inferences “can be drawn only from proven facts and cannot be based upon a foundation of pure conjecture, speculation and guess. ”  Rivera v. Columbus Cadet Corps. of America, 59 N.J. Super. 445, 449 (App. Div. 1960), certif. denied, 32 N.J. 349 (1960).  The plaintiff bears not only the burden of proving defendant’s negligence, but also “that such negligence was a proximate cause of plaintiff’s injury. ”  Dziedzic, 53 N.J. at 161.  In Hansen, the court stated:  It is well settled that the existence of a possibility of a defendant’s responsibility for a plaintiff’s injuries is insufficient to impose liability.  “In the absence of direct evidence, it is incumbent upon the plaintiff to prove not only the existence of such possible responsibility, but the existence of such circumstances as would justify the inference that the injury was caused by the wrongful act of the defendant and would exclude the idea that it was due to a cause with which defendant was unconnected.  While proof of certainty is not required, the evidence must be such as to justify an inference or probability as distinguished from the mere possibility of negligence on the part of defendant. ”  8 N.J. at 141, quoting Callahan v. National Lead Co., Titanium Division, 4 N.J. 150, 154-55 (1950).  Negligence is a fact which must be proved and will never be presumed.  Nor will the mere proof of the occurrence of an accident raise a presumption of negligence.  *Nelson v. Fruehauf Trailer Co.*, 11 N.J. 413, 416 (1953).  “It is well-settled law that a recovery for damages cannot be had merely upon proof of the happening of an accident.  Negligence is never presumed; it, or the circumstantial basis for the inference of it, must be established by competent proof presented by the Plaintiff. ”  *Mockler v. Russman*, 102 N.J. Super. 582, 588 (App. Div. 1968).  Here, as the trial court correctly held, Plaintiff had not – and could not – produce any competent, non-speculative evidence to show that anything [...] did caused the alleged incident.