Begley v. State, 234 Conn. App. 820 (2025)

whether they are contained in a complaint or a brief.
         . . . Further, unadmitted allegations in the pleadings
         do not constitute proof of the existence of a genuine
         issue as to any material fact. . . . Mere statements of
         legal conclusions . . . and bald assertions, without
         more, are insufficient to raise a genuine issue of material
         fact capable of defeating summary judgment.’’ (Citation
         omitted; internal quotation marks omitted.) Martin v.
         Westport, 108 Conn. App. 710, 721–22, 950 A.2d 19
         (2008).
            ‘‘[I]t [is] incumbent upon the party opposing summary
         judgment to establish a factual predicate from which
         it can be determined, as a matter of law, that a genuine
         issue of material fact exists. . . . [M]aterial facts are
         those that will make a difference in the case, and they
         must be pleaded.’’ (Citation omitted; internal quotation
         marks omitted.) Martinez v. Premier Maintenance,
         Inc., 185 Conn. App. 425, 455, 197 A.3d 919 (2018).
            ‘‘[A] party may not rely on mere speculation or conjec-
         ture as to the true nature of the facts to overcome a
         motion for summary judgment. . . . A party opposing
         a motion for summary judgment must substantiate its
         adverse claim by showing that there is a genuine issue
         of material fact together with the evidence disclosing
         the existence of such an issue.’’ (Internal quotation
         marks omitted.) Id., 456. ‘‘A mere assertion of fact in
         the affidavit of the party opposing summary judgment
         is not enough to establish the existence of a material
         fact that, by itself, defeats a claim for summary judg-
         ment.’’ (Internal quotation marks omitted.) Id., 451.
           ‘‘The standard applicable to the plaintiff’s claim of
         . . . retaliation is the McDonnell Douglas-Burdine11
         model of analysis. . . . Under this framework, the
           11
              See Texas Dept. of Community Affairs v. Burdine, 450 U.S. 248, 252–56,
         101 S. Ct. 1089, 67 L. Ed. 2d 207 (1981); McDonnell Douglas Corp. v. Green,
         411 U.S. 792, 802–804, 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1973).
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