New Hampshire summary judgment: page, paragraph and line references, and a 25-page cap
New Hampshire procedure · Last verified August 17, 2026
New Hampshire runs summary judgment on RSA 491:8-a, and its Superior Court rule adds the filing discipline: specific page, paragraph and line references, only the material actually cited, and a hard 25-page limit on each side.
The rule states its own purpose — "to avoid unnecessary and duplicative filing of materials with the court" — which tells you how it will be applied.
The citation and page requirements
N.H. Super. Ct. R. 12(g)(1):
Motion for Summary Judgment. Motions for summary judgment shall be filed, defended and disposed of in accordance with the provisions of RSA 491:8-a as amended. Such motions, objections thereto and supporting memoranda to such motions and objections shall provide specific page, paragraph, and line references to any pleadings, depositions, answers to interrogatories, responses to requests for admission, affidavits, or other evidentiary documents filed with the court in support of or in opposition to the Motion for Summary Judgment. Only such materials as are essential and specifically cited and referenced in the motion, objection, and supporting memoranda shall be filed with the court. In addition, except by permission of the court received in advance, no motion and supporting memorandum if filed, together shall exceed 25 double-spaced pages and similarly no objection and supporting memorandum, if filed, together shall exceed 25 double-spaced pages. The purpose of this rule is to avoid unnecessary and duplicative filing of materials with the court. Excerpts of documents and discovery materials shall be used whenever possible.
| Requirement | Detail |
|---|---|
| Governing law | RSA 491:8-a |
| Citations | specific page, paragraph and line references |
| What may be filed | only materials essential and specifically cited |
| Page limit, motion + memorandum | 25 double-spaced pages |
| Page limit, objection + memorandum | 25 double-spaced pages |
| Exceeding it | only by permission received in advance |
| Form of exhibits | excerpts whenever possible |
Three of these catch people out.
Line-level citation. Page and paragraph are common; New Hampshire also wants the line.
Only cited material may be filed. Attaching a full deposition transcript, or a document you never cite, is contrary to the rule. Use excerpts.
Permission must come in advance. Filing 30 pages and asking forgiveness afterwards is not the mechanism the rule provides.
The statement of material facts
Rule 12(g)(2) requires a separate statement:
Moving Party's Statement of Material Facts. (a) Content. Every motion for summary judgment or its supporting memorandum shall be accompanied by a separate statement of the material facts as to which the moving party
The statement is separate from the memorandum, and it accompanies either the motion or the memorandum. Build it as its own document.
Where this connects
New Hampshire's default rule is Superior Court Rule 42, and striking a default requires a motion and an affidavit of defense setting out the defense and the facts behind it. Its Rule 29(d) also creates a conditional default for unanswered written discovery, curable within 10 days by both answering and moving to strike. See striking off a New Hampshire default.
For the answer itself, see responding to a New Hampshire complaint.
How New Hampshire compares
| New Hampshire | Vermont | Maine | Federal | |
|---|---|---|---|---|
| Governing authority | RSA 491:8-a plus Rule 12(g) | Rule 56 | Rule 56 | Rule 56 |
| Line-level record citations required | yes | no | no | no |
| Page limit | 25 pages each side | no | no | local rule |
| Only cited material may be filed | yes | no | no | no |
| Separate statement of material facts | yes | no | no | no |
A short checklist
- Read RSA 491:8-a alongside the rule; the statute governs the substance.
- Cite page, paragraph and line for every record reference.
- File only what you cite, and use excerpts rather than whole documents.
- Keep motion plus memorandum to 25 double-spaced pages — and the same for an objection.
- Ask permission in advance if you genuinely need more.
- Prepare the statement of material facts as a separate document.
Where these rules live
- N.H. Super. Ct. R. 12 — Motions — Specific
- N.H. Super. Ct. R. 29 — Discovery Motions
- N.H. Super. Ct. R. 42 — Default
This page explains what the rules say. It isn't legal advice, and what makes a factual issue genuine or material is developed in case law this site doesn't cover.