IN THE COURT OF COMMON PLEAS

[COUNTY NAME] COUNTY, OHIO

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.

Case No.: [_]
Judge: [_]

MOTION OF [MOVANT] FOR SUMMARY JUDGMENT

[// GUIDANCE: Title tracks Ohio Civ.R. 56 terminology.]

TABLE OF CONTENTS

1. Motion………………………………………………………………………………….. 1
2. Memorandum in Support………………………………………………………… 2
   2.1 Introduction…………………………………………………………………… 2
   2.2 Statement of Undisputed Material Facts………………………… 2
   2.3 Summary-Judgment Standard………………………………………… 4
   2.4 Argument………………………………………………………………………. 5
   2.4.1 Issue 1: [_]…………………………………… 5
   2.4.2 Issue 2: [_]…………………………………… 7
   2.5 Conclusion…………………………………………………………………… 9
3. Certificate of Compliance with Local Rule Page Limits………… 10
4. Certificate of Service…………………………………………………………… 11
5. Proposed Order…………………………………………………………………… 12

1. MOTION

Pursuant to Ohio Civ.R. 56, [Movant Name] (“Movant”) respectfully moves this Court for summary judgment on all claims asserted by [Opposing Party] and on Movant’s counterclaims as detailed herein. There is no genuine issue as to any material fact and Movant is entitled to judgment as a matter of law.

This Motion is supported by the attached Memorandum in Support, the Statement of Undisputed Material Facts, the pleadings and papers on file, the sworn affidavits and exhibits referenced herein, and any oral argument the Court may allow.

WHEREFORE, Movant requests that the Court grant summary judgment in Movant’s favor and enter the Proposed Order submitted herewith.

Respectfully submitted,

[COUNSEL NAME] (Bar No. ______)
[Law Firm]
[Address] | [Phone] | [Email]
Counsel for [Movant]

2. MEMORANDUM IN SUPPORT

2.1 Introduction

This case arises out of [brief description]. After discovery, the material facts are undisputed. Applying Ohio Civ.R. 56(C) and construing the evidence most strongly in favor of [Non-Movant], no reasonable trier of fact could find for [Non-Movant] on any claim.

2.2 Statement of Undisputed Material Facts

[// GUIDANCE: Number each fact for ease of citation and attach pinpoint record references.]

1. On [date], [Fact 1]. (Ex. 1, ⟂ ¶ __)
2. [Fact 2] is established by [citation].
   …
   n. No evidence contradicts the foregoing facts. (Rule 56(E) affidavits at Exs. –).

2.3 Summary-Judgment Standard

Under Ohio Civ.R. 56(C), summary judgment shall be rendered forthwith if (1) no genuine issue of material fact exists; (2) the moving party is entitled to judgment as a matter of law; and (3) reasonable minds can come to but one conclusion, construed most strongly in favor of the non-moving party.

The movant initially bears the burden of pointing to portions of the record showing the absence of a genuine issue. If that burden is met, the non-movant must set forth specific facts showing a genuine dispute. Ohio Civ.R. 56(E).

2.4 Argument

2.4.1 Issue 1: [Legal Theory/Claim 1]

1. Element A – Undisputed.
2. Element B – Undisputed.
   • Support: [Fact #] & Ex. __.
   Because each required element is satisfied and [Non-Movant] cannot produce contrary evidence admissible under Civ.R. 56(C), Movant is entitled to judgment on Claim 1.

2.4.2 Issue 2: [Legal Theory/Claim 2]

[Repeat structure.]

2.5 Conclusion

For the foregoing reasons, the Court should grant Movant’s Motion for Summary Judgment, dismiss all claims against Movant with prejudice, and enter judgment on Movant’s counterclaims in the amount of $[__] plus interest and costs.

3. CERTIFICATE OF COMPLIANCE WITH LOCAL RULE PAGE LIMITS

I certify that this memorandum contains [] pages, exclusive of the caption, certificates, and signature block, and therefore complies with [Local Rule ] limiting memoranda to [__] pages.

[Attorney Name]

4. CERTIFICATE OF SERVICE

I certify that on [date], a true copy of the foregoing Motion for Summary Judgment was served via [method permitted by Civ.R. 5(B)] upon:
[Opposing Counsel Name & Address].

[Attorney Name]

5. PROPOSED ORDER

IN THE COURT OF COMMON PLEAS
[COUNTY NAME] COUNTY, OHIO

[CAPTION AS ABOVE]

Upon consideration of Movant’s Motion for Summary Judgment, all opposing memoranda, evidence, and oral argument, the Court finds that there is no genuine issue as to any material fact and Movant is entitled to judgment as a matter of law pursuant to Ohio Civ.R. 56. Therefore,

IT IS ORDERED, ADJUDGED, AND DECREED that:
1. Movant’s Motion for Summary Judgment is GRANTED.
2. All claims of [Non-Movant] are DISMISSED with prejudice.
3. Judgment is entered in favor of Movant on its counterclaims in the amount of $[__], plus statutory interest from [date] and court costs.

SO ORDERED.

JUDGE [__]
Date: ____

[ATTACHMENTS LIST]

1. Affidavit of [Name] (Ex. 1)
2. [Deposition Transcript Excerpts] (Ex. 2)
3. [Contracts / Records] (Exs. 3–__)
   [// GUIDANCE: Attach only materials admissible under Civ.R. 56(C).]

KEY OHIO-SPECIFIC COMPLIANCE NOTES

[// GUIDANCE: These drafting notes are for attorney use and should be removed before filing.]

• Summary-Judgment Standard: Track Civ.R. 56(C) language verbatim to avoid mis-statement.
• Evidence: Acceptable materials are limited to the enumerated list in Civ.R. 56(C); uncertified documents require a properly framed affidavit authenticating them.
• Briefing Limits: Confirm county-specific local rules for page limits, font size, and reply-brief deadlines (often 7–14 days).
• Scheduling: Some Ohio counties (e.g., Franklin C.P. Loc.R. 56.01) require a Non-Oral Hearing Date; insert “[Hearing Date]” in the Notice if applicable.
• Proposed Order: Most judges expect a Word-processing version emailed to chambers—check standing orders.

[// GUIDANCE: Replace all bracketed placeholders before filing. Verify citations to exhibits. Remove guidance comments prior to submission to the court.]