Oregon Sample Letter for Response in Connection with Motions for Summary Judgment Date: [Date] [Your Name] [Your Address] [City, State, ZIP] [Your Email Address] [Your Phone Number] [Attorney's Name] [Attorney's Address] [City, State, ZIP] [Attorney's Email Address] [Attorney's Phone Number] Re: Response to Motion for Summary Judgment Case: [Case Number] Court: [Court Name] Dear [Attorney's Name], I hope this letter finds you well. I am writing in response to the Motion for Summary Judgment filed by [Opposing Party's Name] on [Date]. As the plaintiff in this case, I strongly oppose the motion and request the court to deny it based on the following grounds: 1. Lack of Genuine Issues of Material Fact: Contrary to what [Opposing Party's Name] states in their motion, there exist genuine issues of material fact in this case. The evidence provided clearly demonstrates that there are disputed facts that require a trial to reach a just resolution. These facts include, but are not limited to: — [Provide specific details of disputed facts and supporting evidence] 2. Credibility of Affidavits and Supporting Documents: [Opposing Party's Name] relies heavily on affidavits and supporting documents that lack credibility and fail to provide a comprehensive understanding of the facts. I contend that certain facts have been misinterpreted or misrepresented, and I will present evidence during trial to refute these claims. It would be inappropriate for the court to grant summary judgment based on these questionable pieces of evidence. 3. Legal Arguments and Precedents: I firmly believe that the legal arguments presented by [Opposing Party's Name] are flawed and do not accurately apply the relevant Oregon laws and court precedents. I will present counter-arguments supported by appropriate legal authorities during the trial to illustrate the incorrect interpretation of the law by [Opposing Party's Name]. 4. Discovery Process: Many crucial pieces of evidence and witnesses that could favorably impact the outcome of this case have yet to be discovered. The summary judgment stage is premature as it does not allow for the completeness of the discovery process. Denying the motion and proceeding to trial would enable the presentation of additional evidence and the examination of relevant witnesses under oath. In view of the above, I request the court to deny the Motion for Summary Judgment filed by [Opposing Party's Name] and to allow this matter to proceed to trial, where all disputed issues can be fully examined, evaluated, and resolved. Please consider this response as my earnest opposition to the Motion for Summary Judgment. I kindly request a hearing on this matter to further discuss the issues raised herein and to present additional legal authorities supporting my position. Thank you for your attention to this matter. I look forward to the court's consideration and remain at your disposal for any further information or clarification. Yours sincerely, [Your Name]