State Court Motion for Summary Judgment
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[LAW FIRM LETTERHEAD]
[Attorney Name], Esq. (Juris No. [_])
[Law Firm Name]
[Office Address]
[City], Connecticut [ZIP]
T: [
--] | F: [--_] | E-mail: [____]
Attorney for [Plaintiff / Defendant]

SUPERIOR COURT OF THE STATE OF CONNECTICUT
JUDICIAL DISTRICT OF [_] AT [_]

[PLAINTIFF NAME(S)], ) Docket No. [__]
Plaintiff, )
v. ) MOTION FOR SUMMARY JUDGMENT
[DEFENDANT NAME(S)], ) (Practice Book §§ 17-44 – 17-51)
Defendant. )
) [Return Date:
_]
) [Motion Filing Date:
___]

TABLE OF CONTENTS

  1. Document Header & Introduction ..................................................... 2
  2. Notice of Motion (Practice Book § 17-45) ........................................... 2
  3. Motion ............................................................................. 3
  4. Memorandum of Law in Support ....................................................... 4
    4.1 Procedural Background .......................................................... 4
    4.2 Applicable Legal Standard ..................................................... 4
    4.3 Statement of Undisputed Material Facts ........................................ 5
    4.4 Argument ...................................................................... 6
    4.5 Conclusion .................................................................... 7
  5. Affidavit(s) & Evidentiary Exhibits (Practice Book § 17-46) ........................ 8
  6. Proposed Order .................................................................... 9
  7. Certificate of Compliance (Practice Book § 17-45(b)) ................................ 9
  8. Certification of Service (Practice Book § 10-12) .................................... 9

[// GUIDANCE: Delete the Table of Contents before filing if not required by the assigned judge’s standing orders.]


1. DOCUMENT HEADER & INTRODUCTION

Pursuant to Practice Book §§ 17-44 through 17-51, [Movant Name] (the “Movant”), by and through undersigned counsel, respectfully moves this Court for the entry of summary judgment in its favor on all claims asserted in the [Complaint / Counterclaim] on the ground that there is no genuine issue as to any material fact and the Movant is entitled to judgment as a matter of law.

2. NOTICE OF MOTION (Practice Book § 17-45)

PLEASE TAKE NOTICE that the undersigned will call the foregoing Motion for Summary Judgment for hearing before the Honorable [Judge’s Name], at the [Judicial District] Courthouse, [Address], on [Hearing Date – at least fifteen (15) days after filing], or as soon thereafter as counsel may be heard.

[// GUIDANCE: Check the judge’s individual calendar procedures; some districts set the hearing date, others require counsel to obtain it from the clerk.]

3. MOTION

NOW COMES the Movant, and hereby moves for summary judgment on Counts [___] of the [Complaint/Counterclaim] pursuant to Practice Book § 17-44 et seq. In support hereof, the Movant relies upon:
a. The accompanying Memorandum of Law;
b. The Local Rule 17-45(a) Statement of Undisputed Material Facts;
c. The Affidavit of [Affiant Name] with Exhibits [A-__]; and
d. The complete record in this action.

WHEREFORE, the Movant respectfully requests that this Court:
1. Grant the Motion for Summary Judgment;
2. Enter judgment in favor of [Movant] on Count[s] [___]; and
3. Award such other and further relief as the Court deems just and proper.

4. MEMORANDUM OF LAW IN SUPPORT

4.1 Procedural Background

[BRIEF, chronological procedural posture of the case.]

4.2 Applicable Legal Standard

Under Practice Book § 17-49, “summary judgment shall be rendered forthwith if the pleadings, affidavits and any other proof submitted 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 burden rests on the moving party to make a prima facie showing; once met, the non-moving party must present evidentiary materials demonstrating the existence of a genuine issue. Id.

4.3 Statement of Undisputed Material Facts

In accordance with Practice Book § 17-45(a) and the Court’s Standing Order, Movant submits the separately filed “Local Rule 17-45(a) Statement of Undisputed Material Facts.” The facts therein are supported by citations to admissible evidence, including deposition transcripts, sworn affidavits, interrogatory responses, and authenticated business records.

[// GUIDANCE: File the Statement as a separate docket entry when required by the clerk’s office.]

4.4 Argument

  1. Title of Legal Issue 1
    a. Sub-Argument 1: [Set forth the undisputed fact and connect it to the legal element.]
    b. Sub-Argument 2: [Demonstrate the absence of dispute and entitlement to judgment.]

  2. Title of Legal Issue 2
    [Same structure.]

[// GUIDANCE: Use numbered headings that correspond to the elements of the claim or defense. Keep legal citations concise; limit to statutes, rules, and well-established treatises.]

4.5 Conclusion

Because the record demonstrates the absence of any genuine dispute of material fact and establishes each element of Movant’s claim/defense as a matter of law, summary judgment should be granted.

5. AFFIDAVIT(S) & EVIDENTIARY EXHIBITS (Practice Book § 17-46)

AFFIDAVIT OF [AFFIANT NAME]
State of Connecticut )
) ss. [City]
County of [_____ ] )

I, [Affiant Name], being duly sworn, depose and say:
1. I am [title/relationship], and I have personal knowledge of the facts set forth herein.
2. [Set out each material fact in numbered paragraphs.]
3. Attached hereto as Exhibit A is a true and correct copy of [document].
4. I make this Affidavit in support of Movant’s Motion for Summary Judgment.


[Affiant Name]

Subscribed and sworn before me on this ___ day of _, 20__.


Notary Public
My Commission Expires: ____

[// GUIDANCE: Attach all supporting documents behind a yellow legal-size divider for the judge’s paper file, if applicable.]

6. PROPOSED ORDER

The Court, having considered the Motion for Summary Judgment, the pleadings, affidavits, exhibits, and arguments of counsel, hereby ORDERS:
A. The Motion for Summary Judgment is GRANTED;
B. Judgment shall enter in favor of [Movant] on Count[s] [___]; and
C. [Any additional relief.]

So Ordered this ___ day of _____, 20__.


Hon. [Judge’s Name]
Superior Court Judge

7. CERTIFICATE OF COMPLIANCE (Practice Book § 17-45(b))

Undersigned counsel certifies that this Motion, Memorandum, and supporting documents do not exceed the word/page limitations, if any, imposed by the Court’s Standing Order dated [_____] and that a separate Statement of Undisputed Material Facts has been filed concurrently herewith.

8. CERTIFICATION OF SERVICE (Practice Book § 10-12)

I hereby certify that a copy of the foregoing Motion for Summary Judgment, Memorandum in Support, Statement of Undisputed Material Facts, Affidavit(s), and Proposed Order was mailed, emailed, or delivered electronically on [Date] to all counsel and self-represented parties of record as follows:

• [Name, Firm, Address, E-mail]
• [Name, Firm, Address, E-mail]


[Attorney Name], Esq.
(Juris No. [______])


OPTIONAL ATTACHMENT: LOCAL RULE 17-45(A) STATEMENT OF UNDISPUTED MATERIAL FACTS

[Use numbered paragraphs. After each fact, provide pinpoint citation to the supporting evidence. Example:]

  1. On January 1, 20__, Defendant executed the Promissory Note in the principal amount of $500,000. (Ex. A, Note § 1).
  2. Defendant has not made any payment on the Note since March 1, 20__. (Ex. B, Aff. ¶ 7).
  3. The outstanding principal balance is $480,000, plus accrued interest of $47,500. (Ex. C, Aff. ¶ 4).

[// GUIDANCE: Keep the statements concise and avoid argumentative wording.]


FILING CHECKLIST

• Motion, Memorandum, Statement of Facts, Affidavit(s), Proposed Order
• Certificate of Compliance & Service
• Exhibits tabbed and indexed
• Hearing date obtained from clerk (≥ 15 days post-filing)
• E-file as separate PDFs per Judicial Branch e-services instructions

[// GUIDANCE: Always confirm any individual judge’s pre-trial orders regarding page limits, courtesy copies, hyperlinks, and oral argument requests.]

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