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Judges may grant partial summary judgment. For example, a judge might rule on some factual issues, but leave others for trial. Alternately, a judge might grant summary judgment regarding liability, but still hold a trial to determine damages.
Stated differently, to successfully defend against summary judgment the non-moving party (you) should seek to demonstrate that indeed there are material facts in dispute. Alternatively, the non-moving party (you) can argue that the undisputed facts support a judgment as a matter of law in your favor.
Examples of summary judgement motions John says that Linda ran a red light and caused the crash. John happens to have a video of Linda running the red light and crashing into him. John's attorney files a motion for summary judgment claiming that: There are no material facts that can be reasonably disputed.
You must include a summary of the legal basis for your opposition, explain the reason you are opposing the motion, and state what you would like the judge to order.
As with any other application made to a court: the usual form of Application Notice (Form N244) should be used to initiate the Application. almost invariably, applications for summary judgment are supported by evidence, in a witness statement. It must be served with the Application Notice.