Memorandum in support of cross-motion for additional discovery pursuant to FRCP 56(f)

Firm Name

Attorney Name

State Bar Number [if required under local rules]

Telephone

Facsimile

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF ________

Name,

Plaintiff,

vs.

Name,

Defendant.

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Case No. ____________

MEMORANDUM IN SUPPORT OF CROSS-MOTION FOR ADDITIONAL DISCOVERY PURSUANT TO FRCP 56(f)

[Cross-movant] hereby submits this Memorandum in support of its Cross-Motion for Additional Discovery pursuant to Federal Rule of Civil Procedure 56(f).

1. STATEMENT OF FACTS

2. ARGUMENT

   A.The Cross-Motion Is Timely.

   Cross-movant brought this cross-motion within [length of time] after receiving service of the summary judgment motion. Cross-movant has [not yet filed opposition/has filed and served opposition concurrently] with this cross-motion. The hearing on the summary judgment motion is set for [date] and cross-movant’s opposition is due on [date].

   Discovery remains open in this case. The discovery...