Draft an outline argument/Submissions for summary judgment should be ordered in favour of the plaintiff. Link each argument back to the relevant paragraph of the affidavit in support (and exhibit where relevant) do not give evidence from the bar table (not admissible). Remember that the following are in favour of your client:

• the defendant has made part payment
• the defendant has filed a bare denial defence
• the evidence in your client's affidavit is uncontested (ie the defendant has not sought to oppose the application) 2. Educational Productions Pty Ltd (Defendant) is a Company incorporated in the State of Queensland, and has two directors, ELIZABETH HIGGINS and BARRY JOHN MURPHY. Now produced and shown to me at the time of swearing this Affidavit marked "SG1" is a copy of an ASIC company extract for the Defendant dated 9 October 2023. 3. The Defendant produces educational films and documentaries that it sells to online and television broadcasters. 4. I worked with the Defendant as a film producer on a contract basis from time to time between January 2019 and January 2023. 5. In late September 2022, I had a conversation at the Defendant's premises with Elizabeth Higgins (Elizabeth) and Barry John Murphy (Barry) in which I said I wanted to make a film about First Nations' football, called Marngrook. I explained to Elizabeth and Barry that Marngrook was an early form of football played by our First Nations' people which was said to be the origin of Australian Rules Football. Barry said: "Eliza and I prefer rugby, but we'll think about it". 6. On 1 October 2022, I met with Elizabeth and Barry at the premises of Educational Productions to discuss the production of the Marngrook film. We verbally agreed that if I produced the film concurrently with other projects by Educational Productions, the film could be marketed as an EP Production. Barry stated that Educational Productions would hold the copyright, and I agreed to receive 35% of the proceeds if the film was sold. We agreed on the title of the film as "Marngrook: First Peoples' Footy - an EP Production." 7. In February and March 2023, I completed the production of the Marngrook film in conjunction with other Educational Productions projects. 8. In or around June 2023, the Defendant began marketing the Marngrook film to TV networks 9. On 21 August 2023, Barry informed me via email that Educational Productions had sold the Marngrook film rights to a television network for $500,000, with payment expected by 31 August 2023. Barry affirmed Educational Productions' commitment to pay me 35% of the sale proceeds. A copy of the email from Barry Murphy, dated 21 August 2023, is attached herewith and exhibited as "SG2". 10. On 1 September 2023, Barry called me and said that the $500,000 received was used to settle Educational Productions tax debt. He assured me that my share would be paid by 30 November 2023 with some instalments before that. 11. Subsequently, I received $10,000 on 1 October 2023 and 1 November 2023 and $5,000 on 1 December 2023, leaving an outstanding balance of $150,000. 12. In the second week of December 2023, I attempted to reach both Barry and Elizabeth through calls and emails, but all went unanswered. Upon contacting Educational Productions' accountant, Eric Colville, I learned they were on an extended European trip and were only checking emails occasionally. 13. I engaged James Harrison & Associates to initiate proceedings against Educational Productions on my behalf, seeking payment of the outstanding amount of $150,000. 14. On 31 of October 2024, the Defendant filed its Defence. Apart from admitting paragraph 1 of the Statement of Claim, the Defendant simply denied the allegations in the Statement of Claim. 15. After my previous solicitor retired, I instructed Leo Cussen Lawyers to take over the conduct of the matter. My lawyers sent a letter to the Defendant's lawyer, reiterating the facts of my claim and enclosing evidence of Barry Murphy's acknowledgment of the debt. No response was received from the Defendant's lawyer. Now produced and shown to me, marked "SG3," is a true copy of that letter. 16. Based on the evidence and the absence of a substantive defence from the Defendant, my lawyers have informed me that as at the date of this Affidavit they have not received any response to that letter and that the Defendant has not filed any amended defence. 17. Accordingly, on 14 October 2024 my solicitors on my behalf filed this Interlocutory Application for summary judgement against the Defendant.