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[// STATE COURT MOTION FOR SUMMARY JUDGMENT — INDIANA TEMPLATE ]
[// Professionally drafted for use in any Indiana state trial court. ]
[// Customize bracketed text, remove guidance comments before filing. ]
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IN THE [COURT NAME] COURT
[COUNTY] COUNTY, INDIANA

[PLAINTIFF NAME], )
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Plaintiff, )
)
v. ) Cause No. [____]
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[DEFENDANT NAME], )
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Defendant. )

PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
(Ind. Trial Rule 56 & Applicable Local Rules)

Plaintiff, by counsel, respectfully moves the Court for summary judgment pursuant to Indiana Trial Rule 56 (“T.R. 56”) and states as follows:

1. No genuine issue of material fact exists as to the claims set forth in Counts [___] of Plaintiff’s [Complaint/Amended Complaint] (the “Claims”), and Plaintiff is entitled to judgment as a matter of law.
2. In support of this Motion, Plaintiff contemporaneously files and serves:
   a. Plaintiff’s Brief in Support of Motion for Summary Judgment (“Supporting Brief”);
   b. Plaintiff’s Designation of Evidence (“Designation”); and
   c. Proposed Order Granting Plaintiff’s Motion for Summary Judgment (“Proposed Order”).
3. Pursuant to T.R. 56(C), the Designation specifically identifies the evidence on which Plaintiff relies, including depositions, affidavits, discovery responses, and documents produced in discovery.
4. Plaintiff has complied with all briefing-length and formatting requirements imposed by T.R. 56 and the Local Rules of the [COURT NAME] Court, including any page-limit or word-count restrictions. [// GUIDANCE: If the county has adopted a local rule imposing specific page or word limits (e.g., “no brief shall exceed 30 pages”), insert the rule citation and confirm compliance here.]
5. Plaintiff respectfully requests that the Court:
   a. GRANT Plaintiff’s Motion for Summary Judgment;
   b. ENTER judgment in favor of Plaintiff and against Defendant on Counts [___];
   c. AWARD Plaintiff its taxable costs pursuant to Ind. Trial Rule 54(D); and
   d. AWARD all other just and proper relief.

Respectfully submitted,

[ATTORNEY NAME] (#__)
Counsel for Plaintiff
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]

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[// SUPPORTING BRIEF ]
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PLAINTIFF’S BRIEF IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT (T.R. 56)

[// GUIDANCE: The Supporting Brief should be filed as a separate document under most local rules, but is provided here for convenience.]

Table of Contents
1. Introduction
2. Statement of Undisputed Material Facts
3. Summary Judgment Standard (T.R. 56)
4. Argument
4.1 Element 1: [Insert heading]
4.2 Element 2: [Insert heading]
4.3 Damages
5. Conclusion

1. Introduction
   • Identify the nature of the dispute and the relief sought.

2. Statement of Undisputed Material Facts
   • Cite each fact exclusively to evidence designated in the concurrently filed Designation.
   • Use sequential numbering for each fact (e.g., “Fact ¶1,” “Fact ¶2”).

3. Summary Judgment Standard
   • Under T.R. 56(C), summary judgment is appropriate when “there is no genuine issue as to any material fact” and the movant is entitled to judgment as a matter of law.
   • The burden shifts to the non-moving party to set forth specific facts showing a genuine issue for trial once the movant demonstrates the absence of disputed material facts (T.R. 56(E)).

4. Argument
   4.1 [Insert first legal element or claim]
   • Apply undisputed facts to each legal element.
   4.2 [Insert second legal element or claim]
   • Same structure.
   4.3 Damages
   • Explain calculation method and cite designated evidence.

5. Conclusion
   • Restate relief requested, cross-referencing Proposed Order.

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[// DESIGNATION OF EVIDENCE ]
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PLAINTIFF’S DESIGNATION OF EVIDENCE IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT (T.R. 56(C))

Plaintiff, pursuant to T.R. 56(C), designates the following evidence, true and correct copies of which are attached hereto and incorporated by reference:

Ex. A Affidavit of [AFFIANT NAME] with Exhibits 1–3
Ex. B Deposition of [DEPONENT NAME] (pp. –)
Ex. C Defendant’s Responses to Plaintiff’s First Interrogatories (Nos. __)
Ex. D Business Records Certification re: [DOCUMENTS]
Ex. E [Additional Evidence]

[// GUIDANCE: Attach or separately file each exhibit, sequentially labeled, with a detailed index for ease of court review.]

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[// PROPOSED ORDER ]
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ORDER GRANTING PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT

This matter comes before the Court on Plaintiff’s Motion for Summary Judgment filed on [DATE]. Having reviewed the Motion, the Supporting Brief, the Designation of Evidence, and any response and reply thereto, and being duly advised, the Court FINDS that no genuine issue of material fact exists and that Plaintiff is entitled to judgment as a matter of law pursuant to Ind. Trial Rule 56.

IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that:

1. Plaintiff’s Motion for Summary Judgment is GRANTED.
2. Judgment is entered in favor of Plaintiff and against Defendant on Counts [___] of the [Complaint/Amended Complaint].
3. Plaintiff is awarded costs under Ind. Trial Rule 54(D) in the amount of $[_____].
4. All other relief not expressly granted herein is DENIED.

SO ORDERED this _ day of ____, 20____.

Judge, [COURT NAME] Court, [County] County, Indiana

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[// CERTIFICATE OF SERVICE ]
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I certify that on [DATE], a copy of the foregoing was served via [E-filing System / U.S. Mail / Hand Delivery / Email] pursuant to Ind. Trial Rule 5(B) on:

[OPPOSING COUNSEL NAME]
[FIRM NAME]
[ADDRESS]
[EMAIL]

[ATTORNEY NAME]

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[// ADDITIONAL GUIDANCE ]
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1. Filing Deadlines
• Under T.R. 56(C), a motion for summary judgment must be filed at least 30 days before the scheduled trial date unless the Court orders otherwise.
• Non-movant’s response is due within 30 days after service; movant’s reply is due within 15 days thereafter (T.R. 56(C)). Confirm whether your local rules alter these timelines.

2. Evidence Requirements
   • Affidavits must be made on personal knowledge, set out admissible facts, and show affirmatively the affiant is competent to testify (T.R. 56(E)).
   • Unsworn statements or inadmissible hearsay will not satisfy the evidentiary burden.

3. Briefing Limits
   • Indiana’s statewide rules do not impose page limits for trial-level summary judgment briefs, but many counties (e.g., Marion, Lake, Allen) do via local rule.
   • Insert a compliance statement in the Motion or Supporting Brief and adjust formatting if a limit applies.

4. Oral Argument
   • Some judges schedule oral argument automatically; others require a separate request. Include a “Request for Oral Argument” paragraph if desired.

5. Citations
   • Follow Bluebook format for statutory or rule citations.
   • Avoid unpublished opinions unless permitted by Ind. Appellate Rule 65(D) and local practice.

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