Philadelphia Cnty. C.P. CP-Orphans' Division Rule 7.3A

(1) General Rules. After the relevant pleadings are closed, but within such time

as not to unreasonably delay trial, and in accord with any case specific case

management Order, any party may file a motion for summary judgment, as

provided in Pa.R.C.P. No. 1035.1 et seq., and this Rule.

(2) Content of the Motion for Summary Judgment. The moving party shall provide

the bases for the entry of summary judgment in a motion divided into

consecutively numbered paragraphs. Each paragraph shall contain as far as

practicable only one material allegation. The moving party must reference in

each allegation the “record” (as that term is defined in Pa.R.C.P. No. 1035.1)

which the moving party wants the Court to consider, and shall attach a copy of

that record as an exhibit. The moving party shall include with the motion a brief

or memorandum of law. The brief or memorandum of law shall provide the Court

with the legal bases for summary judgment in light of the allegations made in the

motion, and shall not reference any fact or pleading not raised in the motion. Any

fact or allegation mentioned in the brief or memorandum of law which is not listed

in the summary judgment motion will not be considered by the Court.

(3) Service of Summary Judgment Motion. The summary judgment motion,

exhibits and brief or memorandum of law must be served on the party or parties

against whom summary judgment is requested, as provided in Pa. O.C. Rule 4.3.

(4) Response to Motion for Summary Judgment. The adverse party or parties

must electronically file a response to the motion for summary judgment within

thirty (30) days of service of the motion, as provided in Pa.R.C.P. No. 1035.3.

The response to the motion shall be divided into paragraphs, numbered

consecutively, corresponding to the numbered paragraphs of the motion for

summary judgment. The response shall state whether each allegation is

admitted or denied. No general denial is acceptable. The factual reasons for the

denial or dispute must be specifically stated and the “record,” (as that term is

defined in Pa.R.C.P. No. 1035.1) supporting the denial or disputed must be

attached as an exhibit. A response may also include additional allegations

demonstrating any genuine issue of material fact, in which event the responding

party must reference and attach a copy of the “record,” (as that term is defined in

Pa.R.C.P. No. 1035.1) which demonstrates the existence of a genuine issue of

material fact.

(5) Any interested party may request oral argument. The Court may require oral

argument, whether or not requested by a party. The Court may dispose of any

motion without oral argument.

CHAPTER IX. AUDITORS AND MASTERS