among these requirements, “they remain distinct concepts and the courts must take care not to conflate them.” Id. The proponent of expert testimony bears the burden at trial to establish these elements of admissibility. Id. However, a party moving in limine under Daubert to preclude testimony by his opponent’s expert must first make a threshold showing sufficient to indicate that his adversary will be unable to meet his burden at trial with regard to the testimony. See Gottstein v. Flying J, Inc., 2001 WL 36102297, at *1 (N.D.Ala. Aug. 22, 2001); see also Andrew I. Gavil, Defining Reliable Forensic Economics in the Post-Daubert/kumho Tire Era: Case Studies from Antitrust, 57 Wash. & Lee L.Rev. 831, 849 & n.76 (2000); cf. Clark v. Coats & Clark, Inc., 929 F.2d 604, 608 (11th Cir.1991) (<HOLDING>). As to the first element, the Eleventh Circuit
recognizing that the burden of proof is an essential element of the claim itself and that one who asserts a claim has the burden of proof that normally comes with it holding that the moving party need not support its motion with affidavits or other evidence if the nonmovant will bear the burden of proof at trial holding that once the moving party meets its burden the nonmoving party is obliged to produce evidence in response recognizing that even where a party has the burden of proof at trial that party need not produce proof supporting his claim in response to a motion for summary judgment unless the movant has first presented evidence that would negate an element of the nonmovants claim or indicates that the nonmovant will be unable to meet his burden at trial it is never enough simply to state that the nonmoving party cannot meet its burden at trial holding that to survive a motion for summary judgment a party must make a showing sufficient to establish the existence of an element essential to that partys case and on which that party will bear the burden of proof at trial