Fill and Sign the Special Civil Part Form

JOHN LAWYER, ESQ. 12 MAIN STREET ANYWHERE, USA Attorneys for Defendant JOHN DOE, Plaintiff, vs. ABC CORPORATION, Defendants. TO: [INSERT] SUPERIOR COURT OF NEW JERSEY [INSERT] COUNTY:LAW DIVISION SPECIAL CIVIL PART DOCKET NO.: CIVIL ACTION DEFENDANT = S NOTICE OF MOTION FOR SUMMARY JUDGMENT ORAL ARGUMENT REQUESTED Sir: PLEASE TAKE NOTICE THAT the undersigned firm, as counsel for defendant, [insert], will apply to the above named Court, at the [insert] County Court House in [insert], New Jersey, or as soon thereafter as counsel may be heard, for an Order seeking a dismissal with prejudice of all claims against defendant [insert] by way of a motion for summary judgment. The order sought will be entered in the discretion of the court unless the attorney or pro se party upon whom it has been served notifies the clerk of the court and the attorney for the moving party or the pro se party in writing within ten days after the date of service of the motion that the responding party objects to the entry of the order. TAKE FURTHER NOTICE that defendant [insert] will rely upon the annexed Certification of [insert] in support of this application. Additionally, a proposed form of Order is also being filed in support of this Notice of Motion. A trial date of [insert], has been assigned to this matter. NOTICE. IF YOU WANT TO RESPOND TO THIS MOTION YOU MUST DO SO IN WRITING. Your written response must be in the form of a certification or affidavit. That means that the person signing it swears to the truth of the statements in the certification or affidavit and is aware that the court can punish him or her if the statements are knowingly false. You may ask for oral argument, which means you can ask to appear before the court to explain your position. If the court grants oral argument, you will be notified of the time, date, and place. Your response, if any, must be in writing even if you request oral argument. Any papers you send to the court must also be sent to the opposing party = s attorney, or the opposing party if they are not represented by an attorney. We are asking the court to make a final decision against you without a trial or an opportunity for you to present your case to a judge. We are requesting that a decision be entered against you because we say that the important facts are not in dispute and the law entitles us to a judgment. If you object to the motion, you must file a written response stating what facts are disputed and why a decision should not be entered against you. JOHN LAWYER, ESQ. Attorneys for [insert] By: DATED: PROOF OF MAILING I hereby certify that on this day the within notice of motion, Certification of [insert] and proposed form of Order were hand delivered to the Motions Clerk of [insert] County in [insert], New Jersey; and, that a copy of same was faxed and mailed this day, to: [insert]. JOHN LAWYER, ESQ. Attorneys for defendant By: DATED: