If a nonmovant shows by affidavit or declaration that, for specified reasons, it cannot present facts essential to justify its opposition, the court may:(1) defer considering the motion or deny it;(2) allow time to obtain affidavits or declarations or to take discovery; or(3) issue any other appropriate order.Under FRCP 56(d), the appropriate course is to file a declaration or affidavit.From the case SPIERER v. [read post]