this is lay advice (from the course)
did your request for admissions and interrogatories result in defense admitting your ultimate facts? then these are admitted into evidence, or introduce your admissible evidence, get it admitted
then file a motion for summary judgment for all counts with memoranda of citations and explanation why your evidence proves the elements
set it to hearing
since opposition did not dispute any of the facts admitted into evidence (they must be admitted first) the court should not waste time deciding the facts, they are already decided...
make sure your facts are ultimate facts, only those which prove the elements of your causes of action (look up those elements and find appellate case law and laws which support),
then go to your hearing with a court reporter and argue that there is no reason for trial, your evidence was admitted and proved all the elements
* Last updated by: SUZANNE7 on 10/10/2019 @ 1:42 AM *