[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Title] [Recipient's Company] [Company Address] [City, State, Zip Code] Subject: Response to Motions for Summary Judgment Dear [Recipient's Name], I hope this letter finds you well. I am writing in response to the motions for summary judgment filed in connection with the case [Case Name] pending before the [Court Name] in Nassau County, New York. Please consider this letter as our opposition to the said motions and our request for the court's denial of the summary judgment in favor of [Opposing Party's Name]. We have thoroughly reviewed the motions and the supporting documents filed by [Opposing Party's Name]. After careful consideration, we believe that genuine issues of material fact still exist in this case, which warrant a proper trial rather than a summary judgment. We aim to present a strong and compelling case against the motion for summary judgment, ensuring that our client's interests are protected and justice is served. Our response is based on the following grounds: 1. Disputed Facts: There are factual disputes as to the events leading to the alleged incident. Our investigation has revealed conflicting testimonies and evidence, requiring a court hearing to determine the truth. These disputed facts are crucial in determining liability and damages. 2. Affidavits and Declarations: We have attached affidavits and declarations from credible witnesses who possess first-hand knowledge of the facts in question. These affidavits directly contradict the statements made by [Opposing Party's Name], demonstrating the existence of genuine issues of material fact. 3. Legal Precedents: We have thoroughly researched relevant case law and statutes that support our client's claims and counter the arguments put forth by [Opposing Party's Name]. These precedents establish that summary judgment should be denied if there are genuine disputes over material facts. 4. Expert Witness Testimony: We intend to present expert witness testimony during trial to provide a comprehensive analysis and interpretation of the evidence. The expert opinions will further strengthen our case and debunk any attempts by [Opposing Party's Name] to obtain summary judgment. In light of the above, we hereby request that the court denies [Opposing Party's Name]'s motions for summary judgment and allow this case to proceed to trial. We firmly believe that a fair and impartial jury should be given the opportunity to evaluate the evidence presented by both parties and make a just determination. Enclosed with this letter, please find the appropriate legal documents supporting our opposition to the motions for summary judgment. We kindly request your prompt acknowledgment of this letter and confirmation of the trial date. Thank you for your attention and cooperation in this matter. We look forward to a fair and just resolution of this case. Should you have any questions or require further information, please do not hesitate to contact me at [Phone Number] or [Email Address]. Sincerely, [Your Name]