Mastering Summary Judgment Motions: Drafting and Legal Strategy

This session introduces summary judgment as a strategic tool available to both parties in litigation. Learn how plaintiffs can use it for liability and damages issues, while defendants can target specific causes of action or elements.

Discover how to build a fact-intensive foundation by knowing your claim elements and tailoring discovery accordingly. This session covers using interrogatories, depositions, and requests for admission to establish undisputed facts from the complaint.

Explore the legal framework of FRCP 56, including full and partial summary judgment options. Learn the two-part standard requiring no genuine dispute of material facts and entitlement to judgment as a matter of law.

This session examines the moving party’s initial burden to establish no genuine issues of material fact exist. Understand what constitutes a material fact and how to properly support assertions with record citations.

Learn how the burden shifts once the moving party meets its obligations, requiring more than metaphysical doubt. Key case law including Orr v. Bank of America and Anderson v. Liberty Lobby establishes that a mere scintilla of evidence is insufficient.

A short break to refresh before continuing with the remaining material. Use this time to review notes and prepare questions for the upcoming sessions.

This session provides guidance on identifying material facts that go to ultimate issues in the case. Learn to distinguish between facts that affect case outcomes versus those that are merely disputed but immaterial.

Understand why facts cited must be admissible at trial under FRCP 56(c). Learn how opposing parties may challenge inadmissible hearsay and how to anticipate these objections when drafting your motion.

Master the crucial skill of drafting effective summary judgment motions with direct, well-cited statements of undisputed facts. Learn to structure legal arguments with clear headings, proper standards, and compelling application of facts to case law.

Learn to wrap up your motion effectively by reminding the court of the relief requested. A strong conclusion reiterates the absence of genuine factual disputes and your entitlement to judgment as a matter of law.

This final session covers critical local rule requirements including affidavit needs, formatting specifications, and exhibit protocols. Learn how non-compliance can result in courts refusing to consider your motion entirely.