How do I as the defendant file a response to a summary judgment notice?

You will have to file an appropriate affidavit stating the facts that are in dispute and perhaps a brief stating the legal reasons why you feel summary judgment should not be granted. A motion for summary judgment is made by a plaintiff because it contends that it is entitled to judgment as a matter of law because, even giving you all benefits of reasonable inferences and resolving all doubts about the evidence against plaintiff from disputed facts, there are no issues of material fact to support your case. In short, if you are being sued for an unpaid debt and you cannot provide facts to show that you do not owe the debt or that for some reason plaintiff is not entitled to collect, then summary judgment will be granted against you. So your obligation is to prepare an affidavit showing the specific facts that show that plaintiff is not entitled to judgment. You may have to prepare a legal brief as well, showing, if you can find any, case law that has similar facts where a summary judgment was denied. The most important thing to show is that there are factual issues that are in dispute and would have to be resolved by a jury. Procedurally, you should check the court rules for how to file the Objection to Entry of Summary Judgment. At the least, look for these things: Does the motion for summary judgment have a specific return date for argument. How many days before the return date of the motion do you have to file your papers in opposition. File as the original and as many copies as the rule require. Send a copy of the papers you file to the attorney making the motion. Go to court on the return day of the motion. Here is a tip: It is possible to challenge part of the summary judgment. For example, assume that you cannot dispute that you owe the debt and that you really have no opposition to summary judgment on the debt itself. But plaintiff will probably seek other things as well, like interest, counsel fees and costs. Challenge the computation of those figures. You might not be able to avoid summary judgment on the debt itself but you might avoid it on the other issues. Sometimes, a plaintiff will drop claims for those other things if it gets a summary judgment on the main debt. So it pays to look at each individual item that makes up the total amount of money plaintiff is seeking. Don't think that because you can't dispute the main debt, that you can't object to the other things.