Fill and Sign the Motion Summary Judgment Form

1 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 Pr ocedure, 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, Defendant s have engage d in conduct meant to harass, cause unnecessary delay, and needlessly increase the cost of l itigation. 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. Defendant s on numerous times on short notice have needlessly requested postponements, and have frequently not show n up for depositions, and other matters relating to this case. 7. Defendants have recently refused to accept Interrogatories and other discov ery 2 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 Defendant s: (Insert names and address es 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 cor rect 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 3 _____________ ___ _________ (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 counse l 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 fo regoing 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 fo llowing counsel of record for Defendants: ___________________________ ___________________________ Names of Attorney Post Office Box ____ ______ ________ ___ ________________________________________ City, State, Zip Code 4 This __ ___ day of __________ __ ________ , 20_ __ __. Respectfully Submitted, _____________________________ Plaintiff ______________________ (Plaintiff’s Name) _____________________________ (Street address) _____________________________ (City, state and zip code) Te lephone No. _______ ______ ________