A motion for summary judgment is a legal document filed by a plaintiff in a Houston, Texas court that requests the court to make a judgment in their favor without the need for a full trial. This motion is typically filed when the plaintiff believes that there are no genuine issues of material fact in the case, and they are entitled to judgment as a matter of law. Keywords: Houston, Texas, plaintiffs, motion for summary judgment, legal document, judgment, trial, genuine issues, material fact, entitled, matter of law. There are different types of Houston, Texas plaintiffs' motions for summary judgment, including: 1. Traditional Motion for Summary Judgment: In this type of motion, the plaintiff argues that there are no genuine issues of material fact and that they are entitled to judgment as a matter of law based on the evidence and legal principles involved in the case. 2. No-Evidence Motion for Summary Judgment: This type of motion is filed when the plaintiff believes that the defendant lacks sufficient evidence to support their claims or defenses. The plaintiff argues that there is no evidence that could reasonably support a verdict in the defendant's favor, and therefore, they are entitled to judgment. 3. Modified or Texas Rule 166a© Motion for Summary Judgment: Under Texas Rule of Civil Procedure 166a(c), a party may move for summary judgment on specific grounds, such as an affirmative defense or the statute of limitations. In this type of motion, the plaintiff argues that there is no genuine issue of material fact regarding a specific ground, and they are entitled to judgment based on that ground. Overall, a Houston, Texas plaintiff's motion for summary judgment is a legal tool used to request the court to rule in their favor without proceeding to a full trial. The key goal is to demonstrate that there are no genuine issues of material fact and that the plaintiff is entitled to judgment as a matter of law. Different types of motions for summary judgment may be employed, depending on the specific circumstances and grounds being argued.