If applicable, incorporate the personal property lease text as paragraph 3. of form 19-9 in this chapter.
Grounds for Summary Judgment—Personal Property Lease
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 a lease agreement, as described in Plaintiff’s original petition on file herein, under which Defendant became obligated to pay Plaintiff for the use of certain property furnished to Defendant by Plaintiff, as evidenced by [describe evidence].
b.Plaintiff performed all his obligations under the agreement by furnishing the specified property 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].