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motion for summary judgment need answer

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Plainiff has file a motion for summary judgment even though the judge ordered mandatory mediation because i file a motion to compel discovery. Plainiff answered motion for discovery with claiming trade secrets and still searchingfor application "contract".

We sent a meet and confer this is what there response was.

they sight Young v Climtro Southeast Distribution Corp 141 GA App 235 (1977) because they claim the answer was a general denial.

They now have included a affidavit from the bank costodian who is a attorney

They only include bank statements still in there motion

The address on the bank statement are at the present address but the account originally opened at a rental property 3 years ago

Does anyone have any sugguestion on a denial or a case law we can sight to counter?

They obviously do not have the contract all they have is the statements

And in the affidavid it does not state tha t he has personal knowledge that i charge the charges and without the contract how can the prove i charged the debt or requested the credit card in the first place.

need to answer tommorrrow.

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