rebutted.” Goodman v. Brock, 83 N.M. 789, 792-93, 498 P.2d 676, 679-80 (1972). Circumstantial evidence is sufficient to present a prima facie case for summary judgment. Cf. Prof'l Insurors, Inc. v. Buck Scott & Son Motor Co., 110 N.M. 299, 303, 795 P.2d 991, 995 (1990) ("The foregoing constitutes circumstantial evidence ... and more is not required to get past a motion for summary judgment.”). Routine organizational acts such as mailing are regularly proved by circumstantial evidence. See Wells Fargo Bus. Credit v. Ben Kozloff, Inc., 695 F.2d 940, 944 (5th Cir.1983) (“Placing letters in the mail may be proved by circumstantial evidence, including customary mailing practices used in the sender’s business.”); Simpson v. Jefferson Standard Life Ins. Co., 465 F.2d 1320, 1324 (6th Cir.1972) (<HOLDING>). {19} The Department provided sufficient
recognizing that proof of a business system of preparing and mailing letters and compliance with such a custom in the particular instance is sufficient to establish proof of mailing holding that mailing of titleregistration forms satisfied mailing requirement because they contributed to success of the scheme recognizing that a mailing must be sufficiently related to the fraudulent scheme to support a charge of mail fraud holding that the first element of mail fraud  knowing participation in a scheme to defraud  can extend beyond the specific mailing and that the loss calculation for a mail fraud conviction may include any loss from the fraudulent scheme that the mailing furthered holding that the burden of proof is on the claimant