Create an introduction. The opening lines of your motion should include your name, involvement in the case, and the action you want the court to take. The first line traditionally begins, "Comes now the defendant," followed by your name. Then you request that the court dismiss the plaintiff's lawsuit. If you want the court to issue an order, then you need to include specific language for the court to use in dismissing the case. Dismissal is a drastic action and should be used only when necessary. Therefore, your introduction should explain why dismissal is appropriate in this case. For example, you may argue that the statute of limitations has expired, there are insufficient parties, or the claim is barred by collateral estoppel. Present your evidence against the plaintiff. Next, you should present evidence that supports your argument that dismissal is warranted. This may include documents, witnesses, and even expert testimony if applicable. You should always provide the court with the basis for any opinion testimony that you offer. Expert witnesses can help establish facts not readily apparent from the record and give opinions on those facts. In addition, experts can testify regarding industry standards, predict future behavior, or suggest remedies. In conclusion, dismissal is a severe action and should be used only when necessary. Therefore, your motion should clearly state why dismissal is appropriate in this case. It should also include relevant evidence to support your argument.