Wyoming Sample Letter for Response in connection with Motions for Summary Judgment [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, ZIP] Re: Response to Motion for Summary Judgment Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to provide a thorough response in connection with the Motion for Summary Judgment filed against me by your counsel on [Date]. I have carefully reviewed the motion and relevant case law and would like to present my arguments in opposition. First and foremost, I would like to highlight that Wyoming law provides for summary judgment when there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law. In this case, however, there exist several disputed issues of fact that necessitate a trial rather than granting summary judgment. 1. Material Facts in Dispute: [Detail specific facts that are in dispute and demonstrate their significance in relation to the case] 2. Legal Arguments Against Summary Judgment: a) [Present an argument against the legal basis for summary judgment, citing applicable Wyoming statutes or case law] b) [Address any potential procedural defects or inconsistencies in the motion] 3. Affidavits and Supporting Documents: a) [Attach any relevant affidavits or witness statements that contradict the opposing party's factual assertions] b) [Include any additional documentary evidence, such as contracts, photographs, or expert reports, that support your position] 4. Precedent and Case Law: a) [Cite relevant Wyoming court decisions that support your position and distinguish them from cases cited by the opposing party] b) [Provide a detailed analysis of how the precedents and case law are applicable to the present case] It is important to emphasize that summary judgment is an extraordinary remedy that should only be granted when there are no genuine issues of material fact. Given the factual disputes in this case, it would be premature to deprive me of my right to present my case before a jury. Granting the motion for summary judgment would not only violate my rights, but it would also undermine the principles of fairness and justice that our legal system upholds. I kindly request that you and your counsel carefully consider this response and the points raised, in order to make an informed decision regarding the pending motion for summary judgment. Please be advised that I reserve the right to supplement this response once all relevant evidence has been fully disclosed. Thank you for your attention to this matter. I look forward to receiving your timely response. Sincerely, [Your Name]