Fill and Sign the General Form of Motion for Summary Judgment by Defendantwith Notice of Motion

IN THE UNITED STATES DISTRICT COURT FOR THE ___________________________ (DISTRICT) OF ____________________________________________ (STATE)____________________________ (DIVISION) ____________________________________________PLAINTIFFV. CAUSE NO. _____-_____ _____________________________________________DEFENDANT Motion for Partial Summary Judgment by Plaintiff on Issue of Liability COMES NOW _______________________________, Plaintiff in the above- styled and numbered cause, by and through its attorney, and respectfully moves, pursuant to Rule 56 of the Federal Rules of Civil Procedure, for a summary judgment on the issue of liability, and requests, pursuant to ___________________________________ (cite applicable statute or rule), a separate trial on the issue of damages. The Motion for Partial Summary Judgment is based on the pleadings, supporting affidavits, and Exhibits A and B attached hereto, and incorporated herein by reference. The issues are more fully detailed in the Memorandum of Authorities in support of a Partial Summary Judgment attached hereto as Exhibit C. These documents show that there is no genuine issue as to any material fact on the liability issue and that Plaintiff is entitled to judgment on the liability issue as a matter of law. WHEREFORE, PREMISES CONSIDERED, ____________________________, Plaintiff in the above-styled and numbered cause, prays that he be granted summary judgment in this cause on the issue of liability, and that a separate trial on the issue of damages be set by this honorable Court, assessing all cost of this action to the Defendant. Respectfully Submitted, ____________________________________ PLAINTIFF By_________________________________ (Name of Attorney) Plaintiff’s Attorney Certificate of Service This is to certify that I, ______________________________________ (Name of Attorney), attorney for _______________________________________, Plaintiff in the above-styled and numbered cause, have this date served a true and correct copy of the above and foregoing Motion for Partial Summary Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Defendant:__________________________________________ (Name of Attorney) Post Office Box _______City, State, Zip Code This the ____day of ______________, 20___. Respectfully Submitted,____________________________________ (Name of Attorney) State Bar No. _____ Attorney for PlaintiffOF COUNSEL: ________________________________________ (Name of Attorney)Post Office Box ______-_________City, State, Zip Code ______________________________________________________Telephone: ______-______-_________ Notice of Motion for Partial Summary Judgment You are notified that on ______________ (date), at _________ (time), or as soon thereafter as counsel can be heard, in Courtroom 000 of the United States District Court for the ________________________ (District) of _______________________________ (State), ____________________ (Division) at the Federal Courthouse at _____________ ________________________________________________________________________ (street address, city, county, state, zip code), Plaintiff ____________________________, through his attorney, will move the court for Partial Summary Judgment for the reasons stated in the above Motion. ____________________________________ PLAINTIFF By__________________________ (Name of Attorney) Plaintiff’s Attorney Certificate of Service This is to certify that I, _________________________________________ (Name of Attorney), attorney for Plaintiff, __________________________________________ , have this date served a true and correct copy of the above and foregoing Notice of Motion for Partial Summary Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Defendant: _________________________________________________ (Name of Attorney) Post Office Box _____________ ________________________________________________________________________ City, State, Zip Code This the ____day of _____________, 20___. ______________________________ (Name of Attorney) State Bar No. _____ Attorney for PlaintiffOF COUNSEL: _____________________________________ (Name of Attorney)Post Office Box _______-_________City, State, Zip Code ______________________________________________________Telephone: _____-_____-________