Plaintiff’s MSJ Package Generator

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Today's Date

Which document you want?(Required)

Plaintiff’s Traditional MSJ

Plaintiff’s No Evidence MSJ

Who is our client?(Required)

Plaintiff

Defendant

Courthouse Floor

Date for Certificate of Service(Required)

Cause Number(Required)

Court type(Required)

Court Location(Required)

Judge(Required)

County

Plaintiff Name(Required)

Defendant Name(Required)

Motion Title(Required)

Comes Now(Required)

Intro title

Introduction(Required)

Basis of Suit(Required)

Defendant’s Answer / Defenses / Counterclaims(Required)

Other Relevant Facts About the Suit(Required)

Background Title

Facts Relevant to the Motion (with citations)(Required)

Summary Judgement Evidence Title

Exhibit 1 – Description of Evidence(Required)

Exhibit 2 – Description of Evidence(Required)

Additional Exhibits

Plaintiff’s Cause of Action Identified(Required)

Elements of Plaintiff’s Cause of Action(Required)

Element 1 of Cause of Action(Required)

How Established by Evidence For Element 1 of Cause of Action(Required)

Element 2 of Cause of Action

How Established by Evidence For Element 2 of Cause of Action

Element 3 of Cause of Action

How Established by Evidence For Element 3 of Cause of Action

Defendant’s Counterclaim Identified(Required)

Explanation of Adequate Time for Discovery(Required)

Elements of Defendant’s Counterclaim Identified(Required)

Element 1 for Counterclaim(Required)

How Disproved by Evidence-Element 1 for Counterclaim(Required)

Element 2 for Counterclaim

How Disproved by Evidence-Element 2 for Counterclaim

Element 3 for Counterclaim

How Disproved by Evidence-Element 3 for Counterclaim

Pleading Facts That Negate Counterclaim(Required)

Why Counterclaim Is Not Viable(Required)

Special Exceptions to Amend Facts(Required)

Affirmative Defense Name(Required)

Affirmative Defense Identified(Required)

Elements of Affirmative Defense(Required)

Element 1 of Affirmative Defense(Required)

How Established by Evidence – Element 1 of Affirmative Defense(Required)

Element 2 of Affirmative Defense

How Established by Evidence – Element 2 of Affirmative Defense

Element 3 of Affirmative Defense

How Established by Evidence – Element 3 of Affirmative Defense

Plaintiff is entitled to a no-evidence summary judgment on defendant’s counterclaim for {identify counterclaim} because there is no evidence to support an essential element of {his/her/its} counterclaim. To prevail on a counterclaim for {identify counterclaim}, the defendant must prove the following: {identify elements of counterclaim}. {For lists of elements for various causes of action, see “Causes of Action,” O’Connor’s Texas Causes of Action, Part 2 (2023 ed.).}
a. {Identify element of counterclaim that lacks evidentiary support} The defendant cannot prevail on {his/her/its} counterclaim for {identify counterclaim} because there is no evidence of {identify element of counterclaim}.
b. {Continue for all other elements that lack evidentiary support}

Argument 1 title(Required)

Argument 1(Required)

Argument 2 Title

Argument 2

Argument 3 Title

Argument 3

Argument 4 Title

Argument 4

Damages Title

Damages Amount(Required)

Explanation of Damages(Required)

Attorney Fees Title

Authority for Attorney Fees (Contract/Statute)(Required)

Conclusion Title

Conclusion

Type of Judgment Requested(Required)

Partial Summary Judgment

Final Summary Judgment

Alternative Relief in Prayer(Required)

Yes

Line Item Order Needed?

YES

Order Main ¶(Required)

Order ¶ 2(Required)

Line Item Orders

Order ¶ 3(Required)

Order ¶ 4(Required)

Order ¶ 5(Required)

Order ¶ 6(Required)

Order ¶ 7(Required)

Order ¶ 8(Required)

Order ¶ 9(Required)

Order ¶ 10(Required)

Order ¶ 11(Required)

Order ¶ 12(Required)

Order ¶ 13(Required)

Order ¶ 14(Required)

Order ¶ 15(Required)

Order ¶ 16(Required)