Via the (new) legal writer, Raymond Ward posted a blog titled How to make your summary-judgment motion more effective. In this post, Mr. Ward features an article by Michael Reitzell, and he writes:

If you’d rather write your summary-judgment motions with the goal of having them granted, then you’ll benefit from reading Michael Reitzell’s article, Focus on the Material Facts for a Successful Motion for Summary Judgment. Michael gives good advice not only on how to focus your motion on the facts that matter, but also on how to respond to an opposition loaded with irrelevant factual assertions. The article is written from a defendant’s perspective, but its advice applies just as well to a plaintiff’s summary-judgment motion.