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Summary Judgment Motion

Draft Summary Judgment Motions in Minutes, Not Days

15 minutes with Para

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Get started with Para

Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

15 minutes with Para

What you'll need

  • Complaint & Answer
  • Discovery Record

Plans from $20 a month, with usage included.

Workflow

Overview

CaseMark's Summary Judgment Motion skill produces a complete, court-ready MSJ filing package from your uploaded case documents. The AI analyzes your complaint, answer, and discovery record to construct a memorandum of points and authorities, statement of undisputed material facts, supporting declarations, and proposed order — all with proper legal citations and jurisdiction-aware formatting.

Drafting a Motion for Summary Judgment is one of the most time-intensive tasks in litigation. Attorneys must meticulously review voluminous discovery records, identify undisputed facts, map evidence to legal elements, and construct persuasive arguments — a process that typically consumes 20 to 40+ hours of billable time per motion.

CaseMark automates the heavy lifting of MSJ preparation by analyzing your case documents and generating a complete filing package with properly structured arguments, pinpoint citations, and numbered undisputed facts. Attorneys can focus their expertise on strategic refinement rather than spending days on initial drafting.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the Summary Judgment Motion skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the Summary Judgment Motion skill for the Garcia matter. I've attached the Complaint & Answer and Discovery Record. Send the finished draft back here as a DOCX.

What Para does

  1. 1. Upload your complaint, answer, and discovery record documents
  2. 2. AI analyzes claims, defenses, and evidence to identify undisputed material facts
  3. 3. Review and customize the complete MSJ filing package with legal arguments and citations
  4. 4. Export in your preferred format (DOCX, PDF) ready for court filing

What you get

  • Caption & Notice of Motion

  • Memorandum of Points and Authorities

  • Statement of Undisputed Material Facts

  • Supporting Declarations

  • Proposed Order

What it handles

  • Complete MSJ filing package with caption, notice, and memorandum of points and authorities

  • Auto-generated Statement of Undisputed Material Facts with pinpoint record citations

  • Legal standard section citing the Celotex trilogy and controlling authority

  • Element-by-element argument mapping undisputed evidence to each claim or defense

  • Supporting declarations and proposed order drafts ready for filing

  • Jurisdiction-aware formatting for federal and state court local rules

Required documents

  • Complaint & Answer

    The operative complaint and answer identifying all claims and defenses at issue in the case

    .pdf, .docx

  • Discovery Record

    Depositions, interrogatory responses, requests for admissions, and document productions with Bates numbers

    .pdf, .docx

Supporting documents

  • Expert Reports

    Expert reports addressing causation, damages, or standard of care relevant to the motion

    .pdf, .docx

  • Contracts or Policies

    Relevant contracts, insurance policies, or agreements if breach or coverage claims are involved

    .pdf, .docx

  • Local Rules Reference

    Applicable local court rules specifying page limits, separate-statement requirements, and formatting

    .pdf, .docx

Why teams use it

Reduce MSJ drafting time from days to minutes while maintaining the analytical rigor courts expect

Ensure every undisputed fact is properly supported with pinpoint citations to admissible evidence

Produce element-by-element arguments that systematically map evidence to each claim or defense

Generate jurisdiction-compliant formatting that adheres to federal and state local rules

Questions

What documents do I need to upload to generate a summary judgment motion?

At minimum, you should upload the complaint and answer along with your discovery record (depositions, interrogatory responses, RFAs, and document productions). CaseMark will use these to identify undisputed facts and map evidence to each element of the claims at issue.

Does CaseMark handle both federal FRCP 56 motions and state court equivalents?

Yes. CaseMark drafts MSJ packages under FRCP 56 as well as state-court equivalents. The AI adapts its legal standard section and formatting to match the applicable jurisdiction and local rules you specify.

Will the motion include proper case citations and legal authority?

Absolutely. CaseMark automatically incorporates the Celotex trilogy and relevant circuit or state authority in the legal standard section. The argument section includes analogous MSJ grants with parenthetical explanations to strengthen your brief.

Can I generate a partial summary judgment motion for specific claims?

Yes. CaseMark allows you to specify which claims or counts you're targeting, and the AI will draft a partial MSJ focused on those issues while properly scoping the caption, argument, and requested relief.

How does CaseMark handle the Statement of Undisputed Material Facts?

CaseMark generates numbered paragraphs, each containing a single discrete factual assertion that is material to an element of a claim or defense. Every fact includes a pinpoint citation to admissible evidence from your uploaded discovery record.

Do I still need to review and edit the output before filing?

Yes. CaseMark produces a comprehensive first draft that dramatically reduces drafting time, but attorney review is essential. You should verify all citations, confirm factual accuracy, and tailor arguments to your specific case strategy before filing.

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