Affidavit Supporting Motion for Summary Judgment by Plaintiff

AFFIDAVIT

IN THE COURT FOR THE JUDICIAL DISTRICT

COUNTY, FLORIDA

DIVISION

VS.

DEFENDANTS

Affidavit of Plaintiff Supporting Motion of Plaintiff for Summary Judgment

State of

County of

(), being first duly sworn, states the following:

1. I am the Plaintiff in the above-entitled action. I submit this Affidavit in support of Plaintiff's Motion for entry of Summary Judgment.

2. The action is brought to recover $ plus costs, including court costs and costs of collection for (set forth the nature of the action such a breach contract, negligence, libel, etc.)

3. The facts and circumstances under which the cause of action arose are as follows: (set forth facts personally known to you)

4. Defendants have engaged in conduct meant to harass, cause unnecessary delay, and needlessly increase the cost of litigation by doing or failing to do the following (describe)

5. Defendants have raised frivolous arguments meant to harass, cause unnecessary delay, and needlessly increase the cost of litigation by doing or failing to do the following (describe)

6. Defendants have denied factual contentions when such contentions were warranted as based on the evidence by doing or failing to do the following (describe)

7. Defendants on numerous times on short notice have needlessly requested postponements, and have frequently not shown up for depositions, and other matters relating to this case by doing or failing to do the following (describe)

8. Defendants have recently refused to accept Interrogatories and other discovery requests of Plaintiff without justification by doing or failing to do the following (describe)

9. The foregoing facts are known by me to be true, of my own knowledge.

10. By reason of the foregoing facts, and after allowing Defendants all just deductions, credits and setoffs, the sum of recover $ plus costs, including court costs and costs of collection is now due and owing from Defendant to Plaintiff.

SWORN to and subscribed before me, this the day of 2

NOTARY PUBLIC

My Commission Expires:

Certificate of Service

This is to certify that I, Plaintiff in the above-styled and numbered cause, have this date served a true and correct copy of the above and foregoing Affidavit of Plaintiff Supporting Motion of Plaintiff for Summary Judgment by U.S. Mail, postage fully prepaid, to the following Defendants:

or

This is to certify that I, , (Name of Attorney), the attorney for (Name of Plaintiff), Plaintiff in the above-styled and numbered cause, have this date served a true and correct copy of the above and foregoing Affidavit of Plaintiff Supporting Motion of Plaintiff for Summary Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Defendants:

Names of Attorney

Post Office Box

City, State, Zip Code

This day of 2

Respectfully Submitted,

Plaintiff

Telephone No.