[// GUIDANCE: Replace every bracketed, ALL-CAPS section with matter-specific information before filing. Delete all GUIDANCE comments prior to service and e-filing.]

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IN THE CIRCUIT COURT OF THE
[] JUDICIAL CIRCUIT, [] COUNTY, ILLINOIS
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[PLAINTIFF NAME], )
)
Plaintiff, )
)
v. ) Case No. [____]
)
[DEFENDANT NAME], )
)
Defendant. )

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NOTICE OF MOTION
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TO: [COUNSEL OF RECORD / PRO SE PARTIES]
PLEASE TAKE NOTICE that on [DATE] at [TIME] a.m./p.m., or as soon thereafter as counsel may be heard, counsel for [MOVANT] will appear before the Honorable [JUDGE’S NAME] in Courtroom [__], [COURTHOUSE ADDRESS], and present [Movant]’s Motion for Summary Judgment pursuant to 735 ILCS 5/2-1005.

Respectfully submitted,

[LAW FIRM NAME]

Date: [] By: ___
One of Its Attorneys
[ATTORNEY NAME] (#ARDC ____)
[ADDRESS] · [PHONE] · [EMAIL]

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CERTIFICATE OF SERVICE
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I certify that on [DATE] I caused a true and correct copy of the foregoing Notice and Motion to be served upon all counsel of record via [E-FILE/EMAIL/U.S. MAIL] pursuant to Ill. Sup. Ct. R. 11.

[ATTORNEY NAME]

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MOTION FOR SUMMARY JUDGMENT
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[Movant], by and through undersigned counsel, respectfully moves this Court for entry of summary judgment in its favor and against [Non-Movant] under 735 ILCS 5/2-1005(c), and states as follows:

1. INTRODUCTION
   1.1 This action concerns [brief description of dispute].
   1.2 No genuine issue of material fact exists; [Movant] is entitled to judgment as a matter of law.

2. JURISDICTION AND VENUE
   2.1 The Court has subject-matter jurisdiction pursuant to Ill. Const. art. VI, § 9.
   2.2 Venue is proper in this County under 735 ILCS 5/2-101.

3. PROCEDURAL HISTORY
   3.1 [Summarize pleadings, prior motions, orders.]

4. UNDISPUTED MATERIAL FACTS
   [// GUIDANCE: Provide numbered, short, single-statement facts. Pinpoint cite to record after each fact (e.g., “(Ex. 1, ¶ 4)” or “(Smith Dep. 12:3-13)”).]

4.1 …
4.2 …

5. APPLICABLE LEGAL STANDARD
   5.1 Under 735 ILCS 5/2-1005(c), summary judgment “shall be rendered” where “the pleadings, depositions, 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 a judgment as a matter of law.”
   5.2 Supporting affidavits must comply with Ill. Sup. Ct. R. 191(a).

6. ARGUMENT
   6.1 Element 1 — [Identify]
   6.1.1 Undisputed Fact Nos. [__] establish [legal conclusion].
   6.2 Element 2 — [Identify]
   6.3 Affirmative Defenses (if any)
   6.4 Damages/Relief
   6.5 Summary

7. CONCLUSION
   WHEREFORE, [Movant] respectfully requests that the Court:
   A. Grant this Motion;
   B. Enter judgment in favor of [Movant] and against [Non-Movant] on Counts [__];
   C. Tax costs against [Non-Movant]; and
   D. Award such further relief as is just.

Respectfully submitted,

[LAW FIRM NAME]

Date: [] By: ______
One of Its Attorneys

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RULE 191(a) AFFIDAVIT OF [NAME/TITLE]
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I, [AFFIANT NAME], being first duly sworn, state:

1. I have personal knowledge of the facts set forth herein and could competently testify thereto.
2. The attached exhibits [identify] are true and correct.
3. All facts herein are admissible and would be admissible at trial.
4. [Additional foundation statements as needed.]

Under penalties of perjury as provided by law pursuant to 735 ILCS 5/1-109, I certify that the statements set forth in this affidavit are true and correct.

[AFFIANT NAME]

Subscribed and sworn before me
on [DATE].

Notary Public

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STATEMENT OF UNDISPUTED MATERIAL FACTS (L.R. [] § [])
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[// GUIDANCE: Some Illinois Circuits (e.g., Cook County Chancery Div. Gen. Admin. Order 6.4) REQURE a separate numbered Statement. Insert or omit per local rule.]

2. …

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MEMORANDUM OF LAW
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[// GUIDANCE: If required or advisable under local rules, place the legal argument in a separate memorandum. Observe any briefing length limits—e.g., Cook Cty. Cir. Ct. R. 2.1(c) generally limits principal briefs to 15 pages unless leave of court is obtained. Include a Table of Contents and Table of Authorities if the memo exceeds 10 pages.]

[Insert expanded legal analysis, discussion of statutory framework, application to facts, counter of any affirmative defenses, etc.]

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PROPOSED ORDER
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IN THE CIRCUIT COURT OF THE [] JUDICIAL CIRCUIT
[] COUNTY, ILLINOIS

[CAPTION AS ABOVE]

This matter coming before the Court on [Movant]’s Motion for Summary Judgment, due notice having been given and the Court being fully advised in the premises:

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED.
2. Judgment is entered in favor of [Movant] and against [Non-Movant] on Count(s) [__].
3. [Optional] The case is dismissed with prejudice.
4. Costs are taxed against [Non-Movant] in the amount of $[__].
5. This order is final and appealable.

DATED: _____, 20__

ENTER: _____
Judge of the Circuit Court

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END OF FILE
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Key Illinois-Specific Compliance Notes
1. Statutory Authority: 735 ILCS 5/2-1005 (summary judgment) and Ill. Sup. Ct. R. 191(a) (affidavit requirements).
2. Evidentiary Foundation: Each factual assertion must be supported by materials that would be admissible at trial (Rule 191(a)). Hearsay within affidavits must either fall under a recognized exception or be excluded.
3. Briefing/Page Limits: Confirm the controlling local rule for the assigned division/county. For example, Cook Cty. Cir. Ct. R. 2.1(c) limits principal briefs to 15 pages absent leave of court. Insert a Certificate of Compliance if required.
4. Separate Statement Requirement: Certain divisions (e.g., Cook County Chancery, Law) mandate a distinct Statement of Undisputed Material Facts. Verify and incorporate as shown above.
5. Service & E-Filing: Serve and e-file pursuant to Ill. Sup. Ct. Rs. 9, 11, and local e-filing G.A.O.s.

[// GUIDANCE: This template intentionally omits case citations in keeping with the drafting instructions. Counsel should insert controlling precedent as appropriate.]