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SAMPLE SUMMARY JUDGMENT MOTION

1 This document provides a SAMPLE of a MOTION for SUMMARY JUDGMENT that sufficientlycomplies with the requirements of the Practice Standards of Judge compliance with Local Rule (A) is not required before filing a Rule 56motion, the Court nevertheless encourages counsel to confer and discuss not only the reliefrequested, but the arguments to be presented in the MOTION . Doing so may lessen or avoidentirely the need for judicial that a separate statement or SUMMARY of the facts is not necessary, nor is arecitation of the SUMMARY JUDGMENT , parties are encouraged to review theCourt s decision inIn re Riobzyme Pharmaceuticals, Inc. Securities Litigation, 209 (D. Colo. 2002) for an extended discussion of the standards applicable to summaryjudgment THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADOH onorable Marcia S. KriegerCase No. 999-cv-99999-MSK-XXXJANE ROE,Plaintiff, CORP.

B. Defendant Smith compared the Plaintiff’s timecard entries with the recollection of the Plaintiff’s supervisor as to her arrival time. Ex. B at 75. He believed in good faith and upon reasonable investigation that the Plaintiff’s timecard was fraudulently endorsed. Ex. B. at 76.

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