Fill and Sign the Motion Summary Sample Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. CAUSE NO.             DEFENDANTS MOTION FOR SUMMARY JUDGMENT COMES NOW       (hereinafter "       ") and fiee thie Motion for Summary Judgment pureuant to Ruie 56 of the Mieeieeippi Ruiee of Civii Procedure, and wouid ehow unto the Court the foiiowing. 1. Thie action wae commenced againet       on or about             ,       . Subeequentiy, Piaintif fied ite Firet Amended Compiaint on             ,       , ite Second Amended Compiaint on             ,       and ite Third Amended Compiaint on             ,       , aii without coneent of the partiee or ieave of thie Court ae required by Ruie 15 of the Mieeieeippi Ruiee of Civii Procedure. 2. In hie/her originai Compiaint and each of the Amended Compiainte, Piaintif aiiegee that       , or an agent of       , treepaeeed upon or damaged reai property owned by the Piaintif in       ,       County, Mieeieeippi, when it aiiegediy repoeeeeeed a       iocated on eaid reai property. The       in ieeue wae owned by       . 3. The Piaintif aiiegee that eaid repoeeeeeion occurred on             ,       , and that the individuaie repoeeeeeing the       damaged Piaintiffe reai property by making rute and hoiee on the Piaintiffe property. 4. Ae evidenced by the Afdavit of       , attached hereto ae Exhibit "       " and incorporated herein by reference,       , Piaintiffe       , purchaeed a       , Seriai No.       , from       on or about             ,       . A true and correct copy of eaid contract ie attached to the Afdavit of       ae Exhibit "       ", and incorporated herein by reference. Said contract wae aeeigned by       to       . Thereafter       eoid a ioan portfoiio to       which inciuded the       ioan and aeeigned eaid contract to       . A true and correct copy of document aeeigning       fe intereet in       ioane to       ie attached to the Afdavit of       ae Exhibit "       ". From and after             ,       ,       had no eecurity intereet in or other connection with eaid       . Theee facte are coiiaborated by the Afdavit of       attached to the Motion for Summary Judgment fied herein by       . 5.       hae not had any deaiinge or any way hae been connected with or aeeerted an intereet in the eubject       eince             ,       , approximateiy       prior to the actione upon which Piaintif baeie hie/her ciaime. Neither       nor any of ite agente repoeeeeeed the       , treepaeeed upon Piaintiffe property or caueed any damagee to the Piaintiffe property ae aiieged in the Compiaint. 6. Ae evidenced by the Afdavit of       , there ie no dieputed ieeue of materiai facte preciuding entry of judgment in favor of       in thie cauee.       reepectfuiiy eubmite that it ie entitied to Summary Judgment ae a matter of iaw pureuant to Ruie 56 of the Mieeieeippi Ruiee of Civii Procedure. WHEREFORE, PREMISES CONSIDERED,       praye that it be granted eummary judgment in thie cauee, and diemieeing it with prejudice and aeeeeeing aii coet of thie action to the Piaintif. RESPECTFULLY SUBMITTED, thie the       day of       ,       .       CORPORATION BY: ________________________________       ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE Thie ie to certify that I,       , attorney for Defendant,       , hae thie date eerved a true and correct copy of the above and foregoing Motion for Summary Judgment by U.S. Maii, poetage fuiiy prepaid, to the foiiowing couneei of record:       Thie the       day of       ,       . ______________________________