[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Name of the Court] [Court's Address] [City, State, ZIP Code] Subject: Proposed Order Granting Summary Judgment — Case No. [Case Number] Dear [Judge's Last Name], I am [Your Name], the attorney representing the [Plaintiff/Defendant] in the aforementioned case. Pursuant to Rule [Rule Number] of the [Applicable Rules of Procedure], I herewith submit this proposed order granting summary judgment on behalf of my client. I. Background information: 1. Case summary: This matter concerns [briefly state the nature of the case, e.g., a breach of contract dispute between the plaintiff and defendant]. 2. Parties involved: The [Plaintiff/Defendant] is represented by [Your Law Firm]. The opposing party [Plaintiff/Defendant] is represented by [Opposing Counsel's Name]. II. Statement of facts: 1. Briefly outline the facts of the case demonstrating a lack of genuine dispute that entitles the moving party to judgment as a matter of law. Provide supporting evidence and citations where necessary. 2. Address any relevant legal arguments raised in the case, demonstrating their failure to establish a genuine dispute. III. Legal analysis: 1. State the applicable legal standard for summary judgment, focusing on the absence of any genuine dispute. 2. Explain how the undisputed material facts support the legal arguments presented by the moving party. 3. Cite relevant case law and statutes that support the legal position. IV. Proposed order: Based on the facts and legal analysis provided above, [Plaintiff/Defendant] respectfully requests that the court grant summary judgment in favor of our client and enter the following order: [Copy and paste the proposed order here, ensuring it complies with the specific requirements set forth by the court's local rules.] Please note that this proposed order is consistent with the [Plaintiff's/Defendant's] [Motion for Summary Judgment/Response to Motion for Summary Judgment], which is also concurrently filed with this submission. V. Conclusion: In conclusion, the evidence presented in this case leaves no genuine dispute as to any material fact, warranting the court's granting of summary judgment. We trust in the court's careful consideration of this matter and respectfully request the proposed order's approval. Thank you for your attention to this matter. We remain at your disposal to provide any additional information or clarification you may require. Yours sincerely, [Your Name] [Your Law Firm] [Your Bar Association Number]