Hi and welcome to JA.I am Ray and I am a licensed lawyer and will be helping you tonight.
You can file an outline of your arguments to the judge here and the other side.You are not required to do so but it is possible.This would also be a great means of organizing your arguments for the court and to make sure you cover them here in oral argument.
If you have the time you can certainly do this to better organize your arguments for your presentation to the court.Remember the other side here has the burden to show that a summary judgment is proper.
I need to make sure I can in Hawaii, can you answer that for me?
You argue there are material fact issues.And yes you can file an outline here with the judge and other party.
And then you can go over them in court during oral argument.
When you say here do you mean Texas or Hawaii?
Hawaii here where your motion is pending and your responses.The court woudl consider it part of your response to their motion.
If you can show any disputed fact issues here at all they loose and it goes to hearing on the merits.
what form would it be in? is it somewhat informal or do I need to have filing cations etc,?
Any of their actions or pleadings leave fact issues again it goes to trial.
I would title it defendant's supplemental response to motion for summary judgment.You would be supplementing your prior pleading with additional information and summary.
There is really no premade form for this you will have to draft and improvise a bit here.
It doesn't hurt to file more paper to try and supplement to your prior pleading.
You are so welcome.
DISCLAIMER: Answers from Experts on JustAnswer are not substitutes for the advice of an attorney. JustAnswer is a public forum and questions and responses are not private or confidential or protected by the attorney-client privilege. The Expert above is not your attorney, and the response above is not legal advice. You should not read this response to propose specific action or address specific circumstances, but only to give you a sense of general principles of law that might affect the situation you describe. Application of these general principles to particular circumstances must be done by a lawyer who has spoken with you in confidence, learned all relevant information, and explored various options. Before acting on these general principles, you should hire a lawyer licensed to practice law in the jurisdiction to which your question pertains.
The responses above are from individual Experts, not JustAnswer. The site and services are provided “as is”. To view the verified credential of an Expert, click on the “Verified” symbol in the Expert’s profile. This site is not for emergency questions which should be directed immediately by telephone or in-person to qualified professionals. Please carefully read the Terms of Service (last updated February 8, 2012).