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A homeowner sued a security-alarm company in federal court after burglars entered through a door that should have triggered an alarm. The company moved for summary judgment six weeks after answering, before any depositions and before producing service logs. The company submitted an affidavit from its operations director saying the alarm system was working when installed and that any failure must have resulted from the homeowner disabling the system.
The homeowner filed a declaration under Rule 56(d). The declaration states that she needs the company's service logs for her account, the technician's installation checklist, and deposition testimony from the technician and operations director. It explains that those materials are expected to show whether the door sensor failed during installation or was later flagged in service records. The company argues that the homeowner's request is just a fishing expedition and that she should already know whether she disabled the system.
How should the court handle the summary-judgment motion? Discuss Rule 56(d), specificity, materiality, diligence, and the court's available options.

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