I know, I know--it doesn't seem possible. But George Lenard says he "love[s] doing summary judgment motions," and it shows in his post "Discourse on Summary Judgment Motions" (George's Employment Blog).
An issue is not genuine if no reasonable jury could buy the plaintiff's story on it . . . So I sometimes confront the uncomfortable facts head on. Even if a judge isn't comfortable saying the plaintiff's not believable, if I can show that to be the case, I then need only show the judge a way out -- another way to avoid the factual issue. And if I lose the motion, I've hopefully warmed the judge up enough to my side of the case to be on the right side of the vast discretion trial judges wield on evidentiary rulings and the like.
There's much more about the theory and practice of summary judgment motions in George's post, including this bit of good advice for citing cases: "Never a naked cite, always use at least a 'sound bite' quote or quick 'parenthetical' spinning the case your way -- but don't spin too hard or you'll lose valuable credibility with the judge and his/her clerks."
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