[COURT NAME] DISTRICT COURT

[COUNTY] COUNTY, STATE OF OKLAHOMA

[PLAINTIFF],
  Plaintiff,

v.

[DEFENDANT],
  Defendant.

Case No.: [CV-20XX-XXX]

DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

[// GUIDANCE: Substitute “Plaintiff” if appropriate]

Filed: [DATE]

TABLE OF CONTENTS

1. Introduction & Relief Requested.............................................................. 2
2. Procedural Posture.................................................................................... 2
3. Statement of Undisputed Material Facts (“SUMF”)................................ 3
4. Applicable Summary-Judgment Standards............................................ 5
5. Argument & Authorities......................................................................... 6
     5.1 Claim One – [Title]........................................................................ 6
     5.2 Claim Two – [Title] (if any)........................................................ 9
     5.3 Additional Claims/Defenses............................................................. 12
6. Conclusion & Prayer for Relief.......................................................... 13
7. Certificate of Service............................................................................ 14
8. Proposed Order (attached).................................................................... 15

[// GUIDANCE: Automatic page numbering is recommended. Oklahoma Uniform Rule for District Courts (“URDC”) 4 limits principal briefs to 30 pages absent leave of court. Keep the substantive sections within that limit.]

1. INTRODUCTION & RELIEF REQUESTED

Pursuant to 12 Okla. Stat. § 2056 and URDC Rule 13, Defendant [NAME] (“Defendant”) respectfully moves this Court for summary judgment on all claims asserted by Plaintiff [NAME] (“Plaintiff”). As demonstrated below, there is no genuine issue as to any material fact, and Defendant is entitled to judgment as a matter of law.

2. PROCEDURAL POSTURE

1. Plaintiff filed its Petition on [DATE].
2. Defendant timely answered on [DATE] and asserted [counterclaims/affirmative defenses] including [DEFENSES].
3. Discovery closed on [DATE] pursuant to the Court’s Scheduling Order.
4. This Motion is timely under URDC Rule 13, having been filed not later than 30 days after the close of discovery.
5. Pursuant to URDC Rule 13(b), Defendant’s supporting brief and SUMF are combined herein.

3. STATEMENT OF UNDISPUTED MATERIAL FACTS (“SUMF”)

[// GUIDANCE: Each fact must be separately numbered, concise, and cite specific record evidence. Attach exhibits and label consecutively (“Ex. 1,” “Ex. 2,” etc.).]

1. On [DATE], Plaintiff and Defendant executed the [TITLE] Agreement (“Agreement”). (Ex. 1, Agreement § __.)
2. The Agreement required Plaintiff to [OBLIGATION]. (Id. § __.)
3. Plaintiff has admitted it did not perform the foregoing obligation. (Ex. 2, Pl.’s Dep. ##:##–##.)
4. Defendant fully performed its contractual duties by [PERFORMANCE]. (Ex. 3, Aff. of [NAME] ¶ __.)
5. Plaintiff suffered no compensable damages because [FACT]. (Ex. 4, Expert Rpt. at __.)

[Add additional facts as needed.]

Compliance Statement: The foregoing SUMF is submitted in the form required by URDC Rule 13(d). Each fact is supported by citation to admissible evidence in the record.

4. APPLICABLE SUMMARY-JUDGMENT STANDARDS

1. Summary judgment shall be rendered “if the pleadings, depositions, answers to interrogatories, 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.” 12 Okla. Stat. § 2056(C).
2. The moving party bears the initial burden of demonstrating the absence of a genuine issue of material fact; the burden then shifts to the non-movant to show that a material fact is in dispute. See URDC R. 13(e).
3. Conclusions or opinions unsupported by specific facts do not create a genuine issue. URDC R. 13(f).

5. ARGUMENT & AUTHORITIES

5.1 Claim One – [TITLE OF CLAIM]

5.1.1 Legal Elements
Under Oklahoma law, [ELEMENT 1], [ELEMENT 2], and [ELEMENT 3] are required for a prima facie claim of [CLAIM].

5.1.2 Application to Undisputed Facts
a. Element 1 – Non-performance: Plaintiff admits non-performance (SUMF ¶ 3).
b. Element 2 – Defendant’s Performance: SUMF ¶ 4 establishes full performance.
c. Element 3 – Damages: SUMF ¶ 5 shows absence of damages.

Because Plaintiff cannot establish [ELEMENTS], the claim fails as a matter of law.

5.1.3 Affirmative Defenses (if any)
Even assuming arguendo a prima facie case, Defendant is entitled to judgment based on [STATUTE OF LIMITATIONS, WAIVER, ETC.]. (SUMF ¶ __.)

[// GUIDANCE: Repeat structure for each cause of action or defense.]

5.2 Claim Two – [TITLE]

[Same analytic framework.]

5.3 Additional Claims/Defenses

[Insert as needed.]

6. CONCLUSION & PRAYER FOR RELIEF

For the foregoing reasons, Defendant respectfully requests that the Court:
1. Grant this Motion and enter judgment in favor of Defendant on all claims;
2. Tax all allowable costs against Plaintiff; and
3. Grant such other and further relief as the Court deems just and proper.

7. CERTIFICATE OF SERVICE

I hereby certify that on the [DATE] day of [MONTH], [YEAR], a true and correct copy of the foregoing Motion for Summary Judgment was served via [METHOD—e-service, certified mail, etc.] on:

[Opposing Counsel Name]
[Law Firm]
[Address]
[Email]

/s/ [ATTORNEY NAME]
[ATTORNEY NAME], OBA #____
[Law Firm]
[Address]
[City, State ZIP]
Telephone: [(###) ###-####]
Email: [EMAIL]

8. PROPOSED ORDER

(Attach as separate document per local practice.)

[// GUIDANCE:
1. Insert a “NOTICE OF HEARING” on a separate page if your district requires setting the motion for hearing at the time of filing.
2. Attach all cited evidentiary materials as numbered exhibits.
3. If page limits under URDC Rule 4 will be exceeded, file a motion for leave contemporaneously.
4. Verify any local district-specific rules that supplement URDC Rule 13 (e.g., Tulsa County LCvR —) and adjust formatting accordingly.
5. Use 12-point Times New Roman, double-spaced text, and 1-inch margins unless local rules differ.
6. Consider filing a separate brief if the court prefers, but URDC 13 allows integration as above.
]