COMES NOW, Defendant, JOY SMITH, by and through her attorney of record, BYRON JUSTICE, ESQ. of the law offices of DAILYAND MYERS, and hereby files her Motion for Summary Judgment according to the standard found in COURT RULE 56(c), establishing that where no material facts are in dispute, a summary judgment may be granted.
This motion is made and based upon the Points and Authorities attached herein, the papers and any oral argument that may be entertained at the time of the hearing on this matter.
Dated this _____ day of _____________, 20__.
By______________________
Bryson Justice, Esq.
Phone Number
Bar Number 93-257
NOTICE OF MOTION AND HEARING
TO: JOHN JOHNSON, Plaintiff; and
TO: BORLAND AND BORLAND, his counsel.
YOUAND EACH OF YOU, WILL PLEASE TAKE NOTICE that the undersigned will bring the foregoing Motion for Summary Judgment on for hearing before the above-entitled court in Dept. 2, on the _____ day of ________, 20__, at the hour of _______ .m. or soon thereafter as counsel can be heard.
Dated this __ day of ____, 20__.
By______________________
Bryson Justice, Esq., Attorney for Defendant Address
Phone Number
Bar Number 93-257
CERTIFICATE OF MAILING
I hereby certify that on this _______ day of ___________, 20__, I placed a true and correct copy of the foregoing MOTION FOR SUMMARY JUDGMENT AND NOTICE, and attached TRIAL BRIEF in the United States mail, postage prepaid, addressed to counsel on the attached list:
(List of names and addresses for opposing counsel here.)
Melissa Ross, Paralegal
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