Plaintiff's Brief in Support of Motion for Summary Judgment - DRAFT
Smith v. Acme Logistics, Inc. - Civil Action No. 24-CV-08217-MAS-DEA Draft v.3 - work in progress
I. Introduction
The undisputed record establishes that Defendant Acme Logistics breached the Warehousing Services Agreement between the parties in at least two independent and material respects.
This Court should grant summary judgment to Plaintiff on the question of liability and reserve damages for trial.
II. Statement of Facts
The parties executed the Warehousing Services Agreement on July 1, 2024. The Agreement obligated Defendant to provide 14,000 square feet of climate-controlled warehouse space and to release inventory within 48 hours of any written request.
Between July and September 2024, Plaintiff fulfilled all monthly storage obligations under the Agreement, paying a total of $187,400 in storage fees without interruption.