How do we respond to a motion for summary judgement on a foreclosure?

Are all the facts alleged in their affidavits correct? If not, file an affadavit giving your version of the material facts.

Have they left out some significant facts in their affidavits? Explain what facts those are, and why they are significant.

Is all the law as applicable as they claim it is? If not, explain why not.

Are there any genuine factual issues which have to be resolved? If so, tell the court which issues those are.