Fill and Sign the Florida Summary Judgment Form

IN THE _________________ COURT FOR THE ___________________ JUDICIAL DISTRICT ____________________ COUNTY, FLORIDA ________________ DIVISION ____________________________ PLANTIFF vs. Case No: _______________ Division _______ ____________________________ ____________________________ ____________________________ ____________________________ DEFENDANTS PLAINTIFF’S MOTION FOR SUMMARY Plaintiff, ________________________, pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, moves for the entry of an Order granting summary judgment in his favor and against Defendants, __________________________________________ ______________________________________________________________________ __________________________________________________, and as grounds states: 1. There are no genuine issues of material fact and Plaintiff therefore is entitled to judgment as a matter of law. 2. This Motion is based on the pleadings filed in this action, as well as the affidavit of Plaintiff, ___________________________. 3. This matter involves an action for damages in the amount of $_______________ plus costs, including court costs and costs of collection. 4. At times material hereto, Defendants have engaged in conduct meant to harass, cause unnecessary delay, and needlessly increase the cost of litigation. Defendants have raised frivolous arguments meant to harass, cause unnecessary delay, and needlessly increase the cost of litigation. 5. Defendants have denied factual contentions when such contentions were warranted as based on the evidence. 6. 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. 7. Defendants have recently refused to accept Interrogatories and other discovery 1 requests of Plaintiff without justification. 8. Defendants have failed to offer a defense to Plaintiff’s Complaint filed in this matter. WHEREFORE, PREMISES CONSIDERED, ___________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, respectfully requests this Court to grant this Motion and enter an Order granting summary judgment in his favor and against the Defendants, jointly and severally, and for such other and further relief as this Court deems just and proper. Respectfully Submitted, _________________________________ Plaintiff 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 Motion for Summary Judgment by U.S. Mail, postage fully prepaid, to the following Defendants: (Insert names and addresses of each Defendant) 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 Motion 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 _____________________, 20_____. Respectfully Submitted, _____________________________ Plaintiff 2 _________________________ (Plaintiff’s Name) _____________________________ (Street address) _____________________________ (City, state and zip code) Telephone No. ____________________ Notice of Motion for Summary Judgment You are notified that on ___________________________ ( date) , at __________ (time) , or as soon thereafter as counsel can be heard, in Courtroom __________ of the ____________________ Court for the ___________________ Judicial District, ____________________ County, Florida, _____________ Division, at the Courthouse located at ______________________________________________________________ ( street address, city, county, state, zip code) , ________________________ , Plaintiff , will move the Court for Summary Judgment for the reasons stated in the above Motion. Respectfully Submitted, ____________________________ Plaintiff 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 Notice of Motion for Summary Judgment by U.S. Mail, postage fully prepaid, to the following Defendants: (Insert names and addresses of each Defendant) 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 Notice of Motion 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 3 This _____ day of ____________________, 20_____. Respectfully Submitted, _____________________________ Plaintiff ______________________ (Plaintiff’s Name) _____________________________ (Street address) _____________________________ (City, state and zip code) Telephone No. _____________________ 4