[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Date] [Court Name] [Judge's Name] [Judge's Address] [City, State, ZIP] Re: [Case Number/Title] Dear Honorable [Judge's Last Name], I, [Your Name], the [Plaintiff/Defendant] in the aforementioned case, hereby submit this letter as a proposed order granting summary judgment in accordance with Rule [State Rule Number] of the [State's] Rules of Civil Procedure. I respectfully request that the Court recognize the merits of my motion, hereby summarized for your consideration. I. Background: Provide a concise overview of the case and the key events leading up to the present motion, explaining the nature of the claims or defenses asserted by both parties. Highlight any significant factual disputes or legal issues essential to the summary judgment analysis. II. Statement of Facts: Present a comprehensive and unbiased summary of the undisputed material facts in the case. Cite the relevant exhibits, affidavits, or depositions that support each fact, ensuring adherence to the local rules of evidence. III. Legal Standard: Explain the legal standard for summary judgment under [State's] Rules of Civil Procedure. Cite relevant case law and statutory provisions, emphasizing the criteria necessary to establish entitlement to summary judgment. IV. Arguments: A. [Plaintiff/Defendant]'s Arguments: Articulate the key legal arguments supporting the granting of summary judgment in favor of the [Plaintiff/Defendant]. Reference specific facts and legal authorities to support each argument and demonstrate how it aligns with the governing standard for summary judgment. B. [Plaintiff/Defendant]'s Response to Opposing Party's Arguments: Address and rebut any arguments presented by the opposing party in their response to the motion for summary judgment. Demonstrate their lack of merit and explain why the facts and applicable law continue to favor the [Plaintiff/Defendant]'s position. V. Conclusion: In conclusion, the evidence presented in this case, when viewed in a light most favorable to the [Plaintiff/Defendant], clearly demonstrates that there are no genuine issues of material fact. Furthermore, the applicable law supports the granting of summary judgment in favor of the [Plaintiff/Defendant]. Accordingly, I respectfully request that this Honorable Court grant the proposed order for summary judgment and provide the necessary relief to ensure the just resolution of this case. Enclosed with this letter, please find a proposed order for your convenience. Thank you for your attention to this matter. I trust in your wisdom and impartiality in making a fair and just decision. Should you require any further information or have any questions regarding this motion, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Sincerely, [Your Name] [Your Attorney's Name, if applicable] [Your Attorney's Bar ID, if applicable]
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Date] [Court Name] [Judge's Name] [Judge's Address] [City, State, ZIP] Re: [Case Number/Title] Dear Honorable [Judge's Last Name], I, [Your Name], the [Plaintiff/Defendant] in the aforementioned case, hereby submit this letter as a proposed order granting summary judgment in accordance with Rule [State Rule Number] of the [State's] Rules of Civil Procedure. I respectfully request that the Court recognize the merits of my motion, hereby summarized for your consideration. I. Background: Provide a concise overview of the case and the key events leading up to the present motion, explaining the nature of the claims or defenses asserted by both parties. Highlight any significant factual disputes or legal issues essential to the summary judgment analysis. II. Statement of Facts: Present a comprehensive and unbiased summary of the undisputed material facts in the case. Cite the relevant exhibits, affidavits, or depositions that support each fact, ensuring adherence to the local rules of evidence. III. Legal Standard: Explain the legal standard for summary judgment under [State's] Rules of Civil Procedure. Cite relevant case law and statutory provisions, emphasizing the criteria necessary to establish entitlement to summary judgment. IV. Arguments: A. [Plaintiff/Defendant]'s Arguments: Articulate the key legal arguments supporting the granting of summary judgment in favor of the [Plaintiff/Defendant]. Reference specific facts and legal authorities to support each argument and demonstrate how it aligns with the governing standard for summary judgment. B. [Plaintiff/Defendant]'s Response to Opposing Party's Arguments: Address and rebut any arguments presented by the opposing party in their response to the motion for summary judgment. Demonstrate their lack of merit and explain why the facts and applicable law continue to favor the [Plaintiff/Defendant]'s position. V. Conclusion: In conclusion, the evidence presented in this case, when viewed in a light most favorable to the [Plaintiff/Defendant], clearly demonstrates that there are no genuine issues of material fact. Furthermore, the applicable law supports the granting of summary judgment in favor of the [Plaintiff/Defendant]. Accordingly, I respectfully request that this Honorable Court grant the proposed order for summary judgment and provide the necessary relief to ensure the just resolution of this case. Enclosed with this letter, please find a proposed order for your convenience. Thank you for your attention to this matter. I trust in your wisdom and impartiality in making a fair and just decision. Should you require any further information or have any questions regarding this motion, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Sincerely, [Your Name] [Your Attorney's Name, if applicable] [Your Attorney's Bar ID, if applicable]
