[INSERT COURT HEADER PER LOCAL RULE]

IN THE CIRCUIT COURT OF [__] COUNTY, VIRGINIA

[PLAINTIFF NAME], )
Plaintiff, )
)
v. ) Case No. [__]
)
[DEFENDANT NAME], )
Defendant. )
________ )

[MOVANT]’S MOTION FOR SUMMARY JUDGMENT

TO: THE HONORABLE JUDGE OF SAID COURT AND ALL PARTIES OF RECORD:

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME] a.m./p.m., or as soon thereafter
as counsel may be heard, [MOVANT] will move the Court, pursuant to Rule 3:20 of the
Rules of the Supreme Court of Virginia, for the entry of Summary Judgment in its favor
for the reasons set forth herein and in the accompanying Memorandum of Law.

[// GUIDANCE: Insert local scheduling/hearing requirements. Some Virginia circuits
require a praecipe or scheduling request to secure a motion date.]

I. INTRODUCTION

1. This action arises out of [BRIEF FACTUAL DESCRIPTION].
2. There exists no genuine issue as to any material fact, and [MOVANT] is entitled
   to judgment as a matter of law.

II. STATEMENT OF UNDISPUTED MATERIAL FACTS

1. [Fact ¶1 — cite record evidence/exhibit].
2. [Fact ¶2 — cite record evidence/exhibit].
3. [...]
   [// GUIDANCE: Number each fact separately. Pin-cite to page/line numbers in
   depositions, interrogatories, admissions, or properly supported affidavits.]

III. SUMMARY JUDGMENT STANDARD

Under Va. Sup. Ct. R. 3:20, summary judgment shall be granted where “the pleadings,
the discovery and disclosure materials on file, and any affidavits show that there is
no genuine issue as to any material fact and that the moving party is entitled to
judgment as a matter of law.”

IV. ARGUMENT

Point I: [Legal Issue #1]
A. Legal Rule
B. Application to Undisputed Facts

Point II: [Legal Issue #2]
A. Legal Rule
B. Application to Undisputed Facts

[Add additional points as needed.]

V. EVIDENTIARY SUPPORT

The motion is supported by the following materials, filed concurrently herewith:

Exhibit A Certified copy of [document]
Exhibit B Deposition transcript of [Name] excerpts (pp. –)
Exhibit C Affidavit/Declaration of [Name] dated [____]
Exhibit D Responses to Request for Admissions (Nos. __)

[// GUIDANCE: Ensure each exhibit is separately tabbed, indexed, and authenticated.
Affidavits/declarations must comply with Va. Code § 8.01-420.6 and Rule 3:20 (b).]

VI. BRIEFING LIMITS & FORMAT COMPLIANCE

This Memorandum contains [] pages, exclusive of the cover, tables, signatures, and
certificates, and therefore complies with the [LOCAL RULE] page limitation of []
pages.

[// GUIDANCE: Many Virginia circuits have no statewide limit; check local rules
(e.g., Fairfax Cir. Ct. Rule 4:15(2) – 20-page limit) and adjust.]

VII. REQUEST FOR ORAL ARGUMENT

Pursuant to Rule 4:15(d), [MOVANT] respectfully requests oral argument.

VIII. CONCLUSION

For the foregoing reasons, and such other reasons as may appear to the Court,
[MOVANT] respectfully requests that the Court:

1. Grant this Motion for Summary Judgment;
2. Enter judgment in favor of [MOVANT] and against [NON-MOVANT] on all counts
   (or specify);
3. Tax costs against [NON-MOVANT]; and
4. Grant such further relief as the Court deems just and proper.

Respectfully submitted this ___ day of [MONTH], [YEAR].

[COUNSEL SIGNATURE BLOCK]

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME] (VSB No. __)
[Address]
[City, State ZIP]
Telephone: [__]
Facsimile: [_]
Email: []
Counsel for [Movant]

CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of [MONTH], [YEAR] a true and correct copy of
the foregoing Motion for Summary Judgment, Memorandum in Support, and all
attachments were served via [METHOD OF SERVICE PER RULE 1:12] upon:

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

[Attorney Name]

=================================================================
PROPOSED ORDER
=================================================================
THIS MATTER came before the Court on [DATE] on the Motion for Summary
Judgment filed by [MOVANT], pursuant to Rule 3:20 of the Rules of the Supreme Court
of Virginia. Upon consideration of the pleadings, evidence, oral argument of
counsel, and for good cause shown, it is hereby

ADJUDGED, ORDERED, and DECREED that:

1. The Motion for Summary Judgment is GRANTED.
2. Judgment is entered in favor of [MOVANT] and against [NON-MOVANT] on
   [all claims / specify counts].
3. The Clerk is directed to tax costs against [NON-MOVANT] pursuant to
   Va. Code § 17.1-601.
4. This Order is FINAL.

ENTERED this ___ day of __, 20__.

Judge, [Circuit] Court of [__] County, Virginia

Seen and Agreed:

Counsel for Movant Counsel for Non-Movant

=================================================================
[// GUIDANCE: End of Template. Tailor factual statements, legal arguments,
and exhibit references to the specific case. Verify and comply with all
local rules (motion scheduling, page limits, font/spacing, filing method),
and attach a Praecipe or Notice of Hearing if required.]