by the latter quoted phrase that a plaintiff is not required to know at the time of pleading all facts necessary to establish the claim. See O’Brien v. Alexander, 101 F.3d 1479, 1489 (2d Cir.1996) (a sanction under Rule 11(b) may not be imposed for failure to make reasonable inquiry “unless a particular allegation is utterly lacking in support”). Similarly, Fed.R.Civ.P. 56(f) provides, as interpreted by court opinions, that when a party facing an adversary’s motion for summary judgment reasonably advises the court that it needs discovery to be able to present facts needed to defend the motion, the court should defer decision of the motion until the party has had the opportunity to take discovery and rebut the motion. See Meloff v. New York Life Ins. Co., 51 F.3d 372, 375 (2d Cir .1995) (<HOLDING>); see also Hellstrom v. U.S. Dep’t of Veteran’s
holding that grant of judgment was premature where plaintiff submitted properly supported rule 56f request for further discovery in opposition to defendants motion for summary judgment holding that arguments not raised in opposition to a motion for summary judgment are waived holding that a court may deny a rule 56f motion where the additional evidence sought for discovery would not have by itself created a genuine issue of material fact sufficient to defeat summary judgment holding that the court was precluded from considering whether the district court had abused its discretion in ruling on defendants summary judgment motion before allowing plaintiff to conduct requested discovery where the plaintiff had not filed an affidavit pursuant to rule 56f and stating that  when a party does not avail himself of relief under rule 56f it is generally not an abuse of discretion for the district court to rule on the motion for summary judgment  citation omitted holding that claims raised for the first time in an opposition to a motion for summary judgment are not properly before a court