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Therefore, if your hearing is set for a Monday, you must give telephone notice to the opposing sides no later than a.m. File a declaration or affidavit telling the Court that you need more time to obtain discovery in order to oppose the Motion.Consider filing your Motion after the completion of discovery because most Motions for. To oppose a motion, you must prepare an affidavit or affirmation. Motion for summary judgment. (e) Compliance with Order Granting Motion in Limine . 202.8-g Motions for Summary Judgment; Statements of Material Facts. Exhibit 35.11.157. This motion asks the court for a judgment on the merits of the case before the trial. Counsel should consider these purposes in determining where to note motions for summary judgment.