[COURT CAPTION]

IN THE CIRCUIT COURT OF THE [___] JUDICIAL CIRCUIT
IN AND FOR [COUNTY] COUNTY, FLORIDA

[PLAINTIFF NAME], Case No. [__]
Plaintiff,

v.

[DEFENDANT NAME], Division: [_]
Defendant.
_____/

DEFENDANT’S MOTION FOR FINAL SUMMARY JUDGMENT

[// GUIDANCE: Replace “Defendant” with “Plaintiff” and adjust pronouns if your client is the moving party.]

TABLE OF CONTENTS
1. Introduction ................................................................................................... 1
2. Statement of Undisputed Material Facts ............................................... 1
3. Summary-Judgment Standard (Fla. R. Civ. P. 1.510) ............................ 3
4. Argument ..................................................................................................... 4
4.1 [First Legal Issue] .............................................................................. 4
4.2 [Second Legal Issue] ....................................................................... 6
4.3 [Additional Issues as Needed] ....................................................... 8
5. Conclusion & Prayer for Relief .............................................................. 9
6. Local Rule Compliance & Certificate of Good-Faith Conference ........ 10
7. Certificate of Service ............................................................................... 11
Proposed Order ........................................................................................... A-1

[// GUIDANCE: Update page numbers after finalizing. TOC can be generated automatically in most word processors.]

I. INTRODUCTION
COMES NOW [Defendant Name] (“Defendant”), by and through undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.510, and respectfully moves this Court for entry of Final Summary Judgment in its favor and against [Plaintiff Name] (“Plaintiff”). As demonstrated herein, there is no genuine dispute as to any material fact and Defendant is entitled to judgment as a matter of law.

[// GUIDANCE: Use a concise overview (1–2 paragraphs) explaining why the facts and law compel judgment.]

II. STATEMENT OF UNDISPUTED MATERIAL FACTS
Pursuant to Fla. R. Civ. P. 1.510(a)–(c), Defendant submits the following numbered facts, each of which is supported by pinpoint record citations and is undisputed for purposes of this Motion:

1. [Fact #1]. (See [Record Cite e.g., “Smith Dep. 12:4-13:2”]).
2. [Fact #2]. (See [Ex. 2, Contract § 3.1]).
3. …
   n. [Final Fact]. (See [Record Cite]).

[// GUIDANCE: Attach all cited evidence as separately-tabbed exhibits. Use concise, non-argumentative language; avoid “spin.”]

III. SUMMARY-JUDGMENT STANDARD
Under Fla. R. Civ. P. 1.510, summary judgment shall be granted “if the pleadings, depositions, answers to interrogatories, admissions, and affidavits on file show that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law.” Fla. R. Civ. P. 1.510(a). The movant bears the initial burden of identifying the absence of a genuine dispute; the burden then shifts to the non-movant to demonstrate specific facts establishing a triable issue. Id.

[// GUIDANCE: The 2021 amendments align Florida’s standard with Fed. R. Civ. P. 56. Avoid case citations unless absolutely necessary and certain.]

IV. ARGUMENT

4.1 [First Legal Issue Heading]
 A. Applicable Law
  [Concise statement of governing statutory/regulatory provisions.]
 B. Application to Undisputed Facts
  [Logical application demonstrating entitlement to judgment.]

4.2 [Second Legal Issue Heading]
 A. Applicable Law
  […]
 B. Application to Undisputed Facts
  […]

4.3 [Additional Issues as Needed]
 […]

[// GUIDANCE: Use clear sub-headings, pinpoint citations to Rule 1.510 evidence, and avoid unnecessary repetition.]

V. CONCLUSION AND PRAYER FOR RELIEF
WHEREFORE, Defendant respectfully requests that this Court:
1. Grant this Motion and enter Final Summary Judgment in favor of Defendant on all claims asserted by Plaintiff;
2. Tax costs against Plaintiff pursuant to Fla. R. Civ. P. 1.525 and any applicable statute; and
3. Award such other and further relief as the Court deems just and proper.

DATED: [Date]

Respectfully submitted,

[ATTORNEY NAME]
Florida Bar No. [_]
[Law Firm Name]
[Address] | [Phone] | [Email]
Counsel for [Defendant Name]

VI. LOCAL RULE COMPLIANCE & CERTIFICATE OF GOOD-FAITH CONFERENCE
Pursuant to [Local Rule or Administrative Order Number], undersigned counsel certifies that he/she conferred with opposing counsel on [Date] regarding the relief sought herein and that Plaintiff [does / does not] oppose this Motion.

[// GUIDANCE: Some Florida circuits require a Rule 1.510(e) statement of compliance; insert as applicable.]

VII. CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via [E-Portal / e-mail / hand delivery] on [Date] upon:
[Name & Address of Opposing Counsel].

[ATTORNEY NAME]

EXHIBIT A – PROPOSED ORDER (Final Summary Judgment)

text
IN THE CIRCUIT COURT OF THE [___] JUDICIAL CIRCUIT
IN AND FOR [COUNTY] COUNTY, FLORIDA

[PLAINTIFF NAME], Case No. [__]
Plaintiff,

v.

[DEFENDANT NAME], Division: [_]
Defendant.
_____/

ORDER GRANTING FINAL SUMMARY JUDGMENT

THIS MATTER came before the Court on Defendant’s Motion for Final Summary Judgment (the “Motion”) filed on [Date]. Having reviewed the Motion, the record evidence, any opposition thereto, and being otherwise fully advised, the Court FINDS:

1. There is no genuine dispute as to any material fact within the meaning of Fla. R. Civ. P. 1.510.
2. Defendant is entitled to judgment as a matter of law.

Accordingly, it is ORDERED AND ADJUDGED:

A. The Motion is GRANTED.
B. Final Summary Judgment is hereby ENTERED in favor of Defendant and against Plaintiff.
C. All pending motions are DENIED as moot.
D. The Clerk is directed to CLOSE this case.
E. The Court reserves jurisdiction to determine entitlement and amount of costs, interest, and any other post-judgment relief.

DONE AND ORDERED in [City], Florida on this _ day of _, 20__.

CIRCUIT COURT JUDGE
Copies furnished to: Counsel of Record

PRACTICAL CHECKLIST
☐ Confirm all exhibits are attached, labeled, and cited.
☐ Verify hearing date complies with Rule 1.510(b) notice periods (motion served ≥ 40 days; response ≥ 20 days).
☐ Insert any page-limit certifications required by local administrative orders.
☐ File via Florida Courts E-Filing Portal and schedule hearing per division procedures.

[// GUIDANCE: Always review the most recent Administrative Orders for the assigned judge/division. Some circuits require hyperlinks to evidence within the PDF.]

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