Form 19-13

If applicable, incorporate the consumer charge account text as paragraph 3. of form 19-9 in this chap­ter.

Grounds for Summary Judgment—Consumer Charge Account

            3.      Grounds.      The pleadings, affidavits, and discovery documents, such as deposition transcripts, answers to interrogatories, and admissions, on file herein or attached hereto show that there is no genuine issue as to any material fact in this cause, in that—

a.Plaintiff and Defendant entered into an agreement, as described in Plaintiff’s original petition on file herein, under which Defendant became obligated to pay Plaintiff for certain goods or services sold to Defendant by Plaintiff, as evidenced by [describe evidence].

b.Plaintiff performed all his obligations under the agreement by delivering the specified goods or services to Defendant, as evidenced by [describe evi­dence].

c.Defendant defaulted in payment of the debt created by the agreement, as evi­denced by [describe evidence].

d.The amount of $[amount] is due by Defendant to Plaintiff under the agree­ment, as evidenced by [describe evidence].