動(dòng)議樣本（簡(jiǎn)約式）
IN THE SUPERIOR COURT FOR
THE DISTRICT OF COLUMBIA
Civil Division
Holy International, Inc. *
51 Iraq Street, Suite 1000 *
Chicago, IL 30012 *
Plaintiff * Case No. CA 0001-05
Vs. * Calendar #12
China Import & Export Corporation * Judge Clir
111 Fuxing Road *
Beijing, China 100014 *
Defendant *
DEFENANT’S MOTION FOR SUMMARY JUDGMENT
The Defendant, China Import & Export Corporation, by and through counsel,
Chang, Wong & Lee, and pursuant to Rule SCR 11, Rule SCR 13-1, and Rule 56 files
this Motion for Summary Judgment and says:
There are no material facts in dispute in the present case and Defendant is
entitled to judgment as a matter of law.
WHEREFORE, for the foregoing reasons and for the reasons set forth in
Defendant’s Memorandum of Law filed herewith and incorporated herein by
reference, the Defendant, China Import & Export Corporation, respectfully requests
that this Court:
1. Grant Defendant’s Motion for Summary Judgment;
2. Award Defendant reasonable attorney’s fees and costs for defending this
action; and
3. Award Defendant such other relief as this court deems just and proper.
Respectfully submitted,
Chang, Wong & Lee, P.C.
_____________________
Robert M. Lee, Esq.
Attorneys for Defendant
China Import & Export Corporation

666 West Main Boulevard
Washington, D.C. 20001
(202) 123-5678
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the foregoing Motion For
Summary Judgment, and accompanying Memorandum of Law in support thereof and
Proposed Order were mailed first class, postage prepaid this 11th day of May, 2005 to
the parties listed below:
Dick B. Chiney, Esq.
Attorney for Plaintiff
567 Putnam Parkway
Suite 112
Chicago, IL 30001
_____________________
Robert M. Lee, Esq.
Attorneys for Defendant
China Import & Export Corporation