Statement of Theories of Recovery and Undisputed Material Facts
(Summary Judgment) (GA)

Summary

This template is a Statement of Theories of Recovery and Undisputed Material Facts for use in civil litigation in Georgia courts. When you move for summary judgment, you must file this Statement in support of your motion pursuant to Uniform Superior Court Rule 6.5. This template contains a caption, signature block, and certificate of service. This template includes practical guidance, drafting notes, and an alternate clause. If you cite to or attach as exhibits supporting affidavits, deposition testimony, discovery responses, or other evidence, you must first file the relevant, original discovery with the court pursuant to O.C.G.A. § 9-11-29.1(a) (1)–(5) and Ga. Unif. Super. Ct. Rule 5.2. For more information on summary judgment motions, see Summary Judgment Fundamentals (GA) and Summary Judgment: Making and Opposing the Motion (GA). For related checklists, see Summary Judgment Checklist (GA) and Summary Judgment: Using Documents as Evidence Checklist (GA).