[PLAINTIFF NAME],
Plaintiff,
v. Civil Action No.: [CASE NO.]
[DEFENDANT NAME],
Defendant.
________/
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
[// GUIDANCE: Replace “Plaintiff” and “Defendant” with the actual party designations used in your case (e.g., “Counter-Plaintiff,” “Third-Party Defendant,” etc.).]
TABLE OF CONTENTS
- Introduction & Relief Requested............................................. 1
- Statement of Undisputed Material Facts...................................... 2
- Standard of Review.......................................................... 4
- Argument.................................................................... 5
4.1 Element One – [INSERT].................................................... 5
4.2 Element Two – [INSERT].................................................... 7
4.3 Element Three – [INSERT].................................................. 9 - Compliance With D.C. Super. Ct. Civ. R. 56 & R. 12-I......................... 11
- Conclusion & Prayer for Relief.............................................. 12
- Request for Oral Hearing (Optional)......................................... 13
- Proposed Order (Ex. A)...................................................... 14
- Certificate of Service...................................................... 15
[// GUIDANCE: Update page numbers after finalizing the brief.]
1. Introduction & Relief Requested
Pursuant to D.C. Super. Ct. Civ. R. 56 and R. 12-I, Plaintiff [PLAINTIFF NAME] (“Plaintiff”) respectfully moves this Court for the entry of summary judgment in its favor and against Defendant [DEFENDANT NAME] (“Defendant”) on Counts [___] of the Complaint. As demonstrated below, there is no genuine dispute as to any material fact and Plaintiff is entitled to judgment as a matter of law.
2. Statement of Undisputed Material Facts
In accordance with D.C. Super. Ct. Civ. R. 56(c)(1) and R. 12-I(k)(1), Plaintiff sets forth the following numbered material facts as to which no genuine dispute exists. Each fact is supported by a pinpoint citation to the record.
- Fact No. 1: [INSERT FACT]. (See [Record Cite]).
- Fact No. 2: [INSERT FACT]. (See [Record Cite]).
- …
[// GUIDANCE: List each fact in a separate, short, numbered paragraph. Cite only evidence already in the record—e.g., deposition excerpts, interrogatory responses, affidavits, or authenticated business records. Attach any new supporting declarations as Exhibit B, etc.]
3. Standard of Review
Under D.C. Super. Ct. Civ. R. 56(a), summary judgment “shall” be granted when “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” See also R. 56(c) (procedure; supporting materials). The movant bears the initial burden of demonstrating the absence of a genuine dispute; the burden then shifts to the non-movant to produce admissible evidence showing a triable issue. Mere allegations or denials are insufficient.
[// GUIDANCE: The language above tracks Rule 56 and avoids case-law citations in keeping with the policy instructions.]
4. Argument
4.1 Element One – [INSERT TITLE]
[Explain why, based on the undisputed facts, Element One of the claim is satisfied. Cross-reference the numbered facts and supporting record cites.]
4.2 Element Two – [INSERT TITLE]
[Analysis.]
4.3 Element Three – [INSERT TITLE]
[Analysis.]
[// GUIDANCE: Create additional subsections for each claim or affirmative defense addressed. Where partial summary judgment is sought, clearly identify the specific issues to be adjudicated.]
5. Compliance With D.C. Super. Ct. Civ. R. 56 & R. 12-I
- Separate Statement: The Statement of Undisputed Material Facts above (Section 2) is submitted as required by R. 12-I(k)(1).
- Record Citations: All record citations comply with R. 56(c)(1)(A).
- Page Limits: This motion does not exceed the [25-page/other] limit imposed by R. 12-I(d).
- Consultation: Pursuant to R. 12-I(a), counsel conferred with opposing counsel on [DATE] regarding the relief requested herein. Opposing counsel [OPPOSES/DOES NOT OPPOSE] the motion.
6. Conclusion & Prayer for Relief
For the foregoing reasons, Plaintiff respectfully requests that the Court:
a. Grant this Motion;
b. Enter judgment in favor of Plaintiff and against Defendant on Counts [___];
c. Award such further relief as the Court deems just and proper.
7. Request for Oral Hearing (Optional)
Pursuant to R. 12-I(e), Plaintiff requests an oral hearing on this Motion and estimates that one hour will be required.
[// GUIDANCE: Delete this section if a hearing is not desired or if the assigned judge dispenses with oral argument.]
8. Proposed Order
See Exhibit A attached hereto.
9. Certificate of Service
I hereby certify that on [DATE], a copy of the foregoing Motion for Summary Judgment, together with all exhibits, was served via [METHOD OF SERVICE] upon:
[DEFENSE COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]
/s/ [ATTORNEY NAME]
[ATTORNEY NAME] (D.C. Bar No. [BAR #])
[LAW FIRM]
[ADDRESS]
[TEL] | [EMAIL]
Counsel for Plaintiff
EXHIBIT A
[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
Upon consideration of Plaintiff’s Motion for Summary Judgment, the opposition thereto, the record herein, and for good cause shown, it is this ___ day of ____ 20__,
ORDERED that the Motion is GRANTED; and it is further
ORDERED that judgment is entered in favor of Plaintiff [PLAINTIFF NAME] and against Defendant [DEFENDANT NAME] on Counts [___] of the Complaint; and it is further
ORDERED that [INSERT any additional relief].
SO ORDERED.
Judge, Superior Court of the District of Columbia
Copies to: All counsel of record.
[// GUIDANCE:
1. File the Motion, Statement of Undisputed Facts (if required as a separate filing), Proposed Order, and all exhibits as separate PDFs in the Superior Court’s eFiling system.
2. Verify current page-limit and consultation requirements under D.C. Super. Ct. Civ. R. 12-I; these are periodically amended.
3. Double-check redaction of personal identifiers under Rule 5.2 and applicable privacy rules before filing.
4. If seeking partial summary judgment, revise the Proposed Order accordingly.]