In my early years practicing law, I knew lawyers who would file motions for summary judgment not with the idea of winning the motion, but with the goal of “educating the judge” about the entire case. I doubt that the judges who had to decide these motions appreciated the educational opportunity, as they were usually made to read lots of stuff having nothing to do with the task at hand: deciding whether to render summary judgment. Not surprisingly, these motions were usually denied.
If you’d rather write your summary-judgment motions with the goal of having them granted, then you’ll benefit from reading Michael Reitzell’s article, Focus on the Material Facts for a Successful Motion for Summary Judgment. Michael gives good advice not only on how to focus your motion on the facts that matter, but also on how to respond to an opposition loaded with irrelevant factual assertions. The article is written from a defendant’s perspective, but its advice applies just as well to a plaintiff’s summary-judgment motion.