IN THE CIRCUIT COURT OF [__] COUNTY, ARKANSAS

[__] DIVISION

[PLAINTIFF NAME],
Plaintiff,

v. Case No. [__]

[DEFENDANT NAME],
Defendant.

DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

[// GUIDANCE: This template provides a consolidated “Motion and Brief in Support.”
Separate briefs are permissible under Ark. R. Civ. P. 56; if your division requires
separate filings, split Sections III–VI into a stand-alone brief and adjust the
certificates accordingly.]

TABLE OF CONTENTS

1. Document Header & Introductory Statement
2. Definitions
3. Statement of Undisputed Material Facts
4. Argument
   4.1 Summary-Judgment Standard (Ark. R. Civ. P. 56)
   4.2 Application of Law to Undisputed Facts
5. Prayer for Relief
6. Reservation of Rights & Additional Defenses
7. Attachments & Supporting Evidence Index
8. Certificate of Service

[// GUIDANCE: Delete the Table of Contents if your court’s e-filing system auto-generates one.]

1. DOCUMENT HEADER & INTRODUCTORY STATEMENT

DEFENDANT [DEFENDANT NAME] (“Movant”), by and through undersigned counsel and pursuant to Ark. R. Civ. P. 56, respectfully moves this Court for the entry of summary judgment in its favor and against Plaintiff [PLAINTIFF NAME] (“Nonmovant”) on all claims asserted in the Complaint filed [DATE].
As set forth below, there is no genuine issue of material fact and Movant is entitled to judgment as a matter of law.

2. DEFINITIONS

The following terms, when capitalized in this Motion, shall have the meanings set forth below:

A. “Action” means the above-captioned civil lawsuit.
B. “Complaint” means the pleading filed by Plaintiff on [DATE] and any amendments thereto.
C. “Court” means the Circuit Court of [__] County, Arkansas.
D. “Rule 56 Materials” means the depositions, sworn affidavits, admissions, interrogatory answers, and other evidence cited herein, as authorized by Ark. R. Civ. P. 56(c).
E. “Undisputed Fact(s)” means a material fact identified in Section 3 that is established through the Rule 56 Materials and not subject to genuine dispute.

[// GUIDANCE: Add or remove defined terms to suit the particular case file.]

3. STATEMENT OF UNDISPUTED MATERIAL FACTS

Pursuant to Ark. R. Civ. P. 56(c)(2), Movant submits the following numbered Undisputed Facts (“UF”) with pinpoint citation to the supporting Rule 56 Materials. Each UF is set out in a separate paragraph for ease of response.

UF-1. [Set out fact] (Ex. 1, ¶ __).

UF-2. [Set out fact] (Dep. Smith 33:17-34:2).

UF-3. …

[// GUIDANCE:
• Attach each evidentiary item as a consecutively‐numbered exhibit.
• For affidavits, include the Rule 56(e) verification language.
• If a local rule imposes a page/word limit for statements of fact, insert compliance language here.]

4. ARGUMENT

4.1 Summary-Judgment Standard

Under Ark. R. Civ. P. 56(c), summary judgment shall be entered “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” The movant bears the initial burden of demonstrating a prima facie entitlement to judgment; the burden then shifts to the nonmovant to meet proof with proof. Ark. R. Civ. P. 56(e).

[// GUIDANCE: The above language tracks the rule verbatim. Insert any controlling local-rule references (e.g., time for response, page limits). Avoid case citations unless absolutely required by the presiding judge.]

4.2 Application of Law to Undisputed Facts

A. Count I – [Breach of Contract / Negligence / Etc.]

1. Legal elements.
2. Each element established by Undisputed Facts.
3. Nonmovant cannot produce contrary Rule 56 evidence.

B. Count II – …

[// GUIDANCE: For each claim, mirror the Complaint’s numbering, align each legal element to specific Undisputed Facts, and expressly negate any affirmative defenses pled by Plaintiff.]

5. PRAYER FOR RELIEF

WHEREFORE, Movant respectfully requests that the Court:

1. Grant this Motion and enter an Order awarding summary judgment in favor of [DEFENDANT NAME] on all claims;
2. Tax all allowable costs against Plaintiff;
3. Grant such other and further relief as the Court deems just and proper.

6. RESERVATION OF RIGHTS & ADDITIONAL DEFENSES

Movant expressly reserves the right to raise additional defenses, file supplemental motions, or seek partial summary judgment on specific issues should the Court determine that any claim, defense, or issue remains for trial.

7. ATTACHMENTS & SUPPORTING EVIDENCE INDEX

Ex. 1 Affidavit of [_] (with exhibits)
Ex. 2 Certified Contract dated [_]
Ex. 3 Deposition Transcript of [Name], vol. I (selected pages)
Ex. 4 [Local Rule Certificate re page limit compliance]
Ex. 5 [Proposed Order Granting Summary Judgment]

[// GUIDANCE: Always include a proposed order; many Arkansas judges require it for e-filing acceptance.]

8. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of [MONTH] 20__, I electronically filed the foregoing Motion for Summary Judgment with the Clerk of the Court using the [ECF / Court’s e-filing] system, which will send notice of such filing to all counsel of record.

[ATTORNEY SIGNATURE BLOCK]

[ATTORNEY NAME] (Ark. Bar No. ______)
[Law Firm]
[Address]
[Telephone]
[Email]
Counsel for Defendant

[// GUIDANCE:
1. Confirm whether the division requires a separate verification or briefing schedule statement.
2. If a hearing is requested, file a separate Notice of Hearing per local practice.
3. For paper filings, add a conventional service statement and signature in ink.]