[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 in good health. I am writing in response to the Motion for Summary Judgment you filed on [date] in the [Court Name] related to the [Case Name or Number]. I have carefully reviewed your motion and the accompanying documents. As the defendant in this case, I respectfully disagree with your motion for summary judgment and intend to vigorously defend my position. Allow me to address the main points of your motion and present my counter-arguments: 1. Summary Judgment Standard: Under New York law, a motion for summary judgment should only be granted if there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. The burden rests on you, as the moving party, to demonstrate that there are no genuine issues of material fact. 2. Genuine Issue of Material Fact: Contrary to your assertion, there exist several material facts that are in dispute and require closer examination. [Present your arguments and evidence disputing facts raised in the opposing party's motion]. 3. Legal Arguments: a. [Name any specific legal principles or statutes relevant to your case, and provide arguments based on them to refute the opposing party's motion]. 4. Supporting Evidence: I have attached herewith affidavits, witness statements, expert reports, and other pertinent evidence that contradict your motion and raise genuine issues of material fact. [Describe the supporting evidence you will be presenting in your defense]. In light of the aforementioned points, it is clear that your motion for summary judgment should be denied. There are material facts in dispute, and it is crucial for this court to consider all relevant evidence through a trial or the appropriate legal proceedings. I respectfully request that the court denies your motion for summary judgment and allows this case to proceed to trial. I trust that the court will decide this matter based on the merits, ensuring justice for all parties involved. Please acknowledge receipt of this letter and the enclosed documents at your earliest convenience. If you are open to discussing a possible resolution to this matter outside of court, I am willing to engage in settlement negotiations. Thank you for your attention and cooperation in this matter. Sincerely, [Your Name]