…the District’s motion for summary judgment argues that, “[p]ursuant to the Development Agreement, any other property owner in the District that wants to further develop its land must first obtain an assignment of development rights from Disney and then obtain written approval from Disney before using those development rights.” Mot. at 8-9 (emphasis added). This assertion only begs questions: Is there any property owner in the District “that wants to further develop its land”? Is there any property owner that could obtain “development rights” to “us[e]”? Some property owners, for example, may be subject to deeds that limit the extent to which new development rights may be received. Because the District has shirked its discovery obligations and Disney has not yet had sufficient time to complete discovery in any event, Disney lacks the opportunity to submit facts demonstrating a dispute as to whether any assertedly “affected” property owner was actually “affected.”