[// GUIDANCE: Replace every bracketed, ALL-CAPS placeholder with matter-specific information. Delete all guidance notes before filing.]

IN THE CIRCUIT COURT FOR [COUNTY], MARYLAND

Civil Action No.: [CASE NO.]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT

(“Motion”)

[// GUIDANCE: File and serve this Motion in strict compliance with Md. Rules 1-321, 2-311, and 2-501, all court scheduling orders, and any applicable local rules (e.g., page-limit or font requirements).]

TABLE OF CONTENTS

1. Introduction & Relief Requested .................................................... [¶ 1]
2. Statement of Undisputed Material Facts (“SUMF”) ............................. [¶ 2]
3. Applicable Legal Standard ............................................................... [¶ 3]
4. Argument ..................................................................................... [¶ 4]
   4.1 Element One – [Specify] ....................................................... [¶ 4.1]
   4.2 Element Two – [Specify] ....................................................... [¶ 4.2]
   4.3 Damages / Entitlement to Relief ............................................ [¶ 4.3]
5. Conclusion & Requested Order ...................................................... [¶ 5]
6. Prayer for Relief ......................................................................... [¶ 6]
7. Proposed Order ............................................................................ [¶ 7]
8. Certificate of Service ................................................................. [¶ 8]

1. Introduction & Relief Requested ¶ 1

Plaintiff, by undersigned counsel and pursuant to Maryland Rule 2-501, respectfully moves for summary judgment against Defendant on all claims asserted in the Complaint. 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 (“SUMF”) ¶ 2

[// GUIDANCE: Present each fact in separately numbered paragraphs, with pinpoint citations to admissible record evidence (affidavits, deposition excerpts, interrogatory answers, certified business records, etc.). Example format:]

1. On [DATE], Defendant executed the [CONTRACT NAME], attached as Exhibit A.
2. The contract obligated Defendant to pay Plaintiff $[AMOUNT] within 30 days. (Ex. A § 3.1).
3. Defendant has not made any payment. (Aff. of [NAME] ¶ 7, Ex. B).
4. The outstanding principal balance is $[AMOUNT], exclusive of accrued interest. (Id.).

3. Applicable Legal Standard ¶ 3

Under Md. Rule 2-501(f), summary judgment “shall be entered” if the record shows (1) there is no genuine dispute as to any material fact and (2) the moving party is entitled to judgment as a matter of law. When a movant properly supports its motion, the opposing party must produce admissible evidence showing a genuine dispute; mere allegations are insufficient. Md. Rule 2-501(b), (e).

[// GUIDANCE: The above rule citations are foundational, well-established, and precisely stated to comply with the Citation Policy.]

4. Argument ¶ 4

4.1 Element One – [Specify Cause of Action Element] ¶ 4.1

[Insert legal analysis applying undisputed facts to first element.]

4.2 Element Two – [Specify Cause of Action Element] ¶ 4.2

[Insert legal analysis applying undisputed facts to second element.]

4.3 Damages / Entitlement to Relief ¶ 4.3

[Explain calculation of damages, entitlement to declaratory or injunctive relief, prejudgment interest, attorneys’ fees if contractually provided, etc.]

[// GUIDANCE: Keep each subsection concise and tethered to cited evidence. Avoid case law citations unless absolutely certain; focus on statutory or rule-based authority.]

5. Conclusion & Requested Order ¶ 5

Because the material facts are undisputed and Plaintiff is entitled to judgment as a matter of law, the Court should grant this Motion, enter judgment in favor of Plaintiff in the amount of $[AMOUNT] plus [prejudgment interest / attorneys’ fees] as provided in [Ex. A § X], and award such further relief as justice requires.

6. Prayer for Relief ¶ 6

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Grant this Motion for Summary Judgment;
B. Enter judgment in the principal amount of $[AMOUNT];
C. Award prejudgment interest from [DATE] through the date of judgment;
D. Award post-judgment interest at the legal rate;
E. Award reasonable attorneys’ fees and taxable costs; and
F. Grant any further relief the Court deems appropriate.

Respectfully submitted,

/s/ [ATTORNEY NAME]
[MD BAR NO.]
[LAW FIRM NAME]
[STREET ADDRESS]
[CITY, STATE ZIP]
[PHONE] | [EMAIL]
Counsel for Plaintiff

7. Proposed Order ¶ 7

[// GUIDANCE: File the Proposed Order as a separate attachment if the judge’s chambers require.]

IN THE CIRCUIT COURT FOR [COUNTY], MARYLAND
Civil Action No.: [CASE NO.]

[PLAINTIFF NAME], Plaintiff,

v.

[DEFENDANT NAME], Defendant.

ORDER

Upon consideration of Plaintiff’s Motion for Summary Judgment, any opposition, the record, and good cause having been shown, it is this _ day of _, 20__, by the Circuit Court for [County], Maryland,

ORDERED, that Plaintiff’s Motion for Summary Judgment is GRANTED; and it is further

ORDERED, that judgment is entered in favor of Plaintiff and against Defendant in the amount of $[AMOUNT], together with prejudgment interest at the rate of [__]% from [DATE] through the date of judgment, post-judgment interest as provided by law, reasonable attorneys’ fees of $[AMOUNT] (if applicable), and costs of suit.

Judge, Circuit Court for [County], Maryland

8. Certificate of Service ¶ 8

I HEREBY CERTIFY that on this _ day of _, 20__, a copy of the foregoing Motion for Summary Judgment, together with all supporting exhibits, was served via [MDEC e-service / first-class mail / hand delivery] on:

[OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL (if e-service)]

/s/ [ATTORNEY NAME]

ADDITIONAL PRACTICE NOTES

[// GUIDANCE: Delete this section prior to filing.]

1. Timing • File the Motion “at any time on or before 30 days before the scheduled trial date” (Md. Rule 2-501(a)).
2. Evidence • Affidavits must be on personal knowledge, set forth admissible facts, and show affiant competency. Attach certified business records or sworn deposition excerpts to avoid hearsay challenges.
3. Page Limits • Check county-specific administrative orders/local rules; some circuits cap memoranda at 35 pages unless leave is granted.
4. Formatting • Use 1-inch margins, 12-point Times New Roman, double-spaced text (headings and block quotes may be single-spaced).
5. Record Citations • Pinpoint cite exhibits (e.g., “Ex. B at 5:13-18”). The court may disregard facts unsupported by precise record references.

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