a. Where various objections and defenses have been consolidated pursuant to Section 2012(E) of Title 12, Oklahoma Statutes, the court should hear jurisdictional objections and defenses first. If the court grants a motion on one of the grounds stated therein, the court may pass over other grounds. If an amendment is filed, the adverse party may renew any ground that was passed over and may object to defects in the amended pleading which did not exist in the initial pleading.

b. In a motion a party must specifically state the grounds therefor and the relief or order sought even where the party relies on defects or deficiencies apparent on the face of the pleading, motion or other instrument.

c. Motions raising fact issues shall be verified by a person having knowledge of the facts, if possible; otherwise, a verified statement by counsel of what the proof will show will suffice until a hearing or stipulation can be provided.

Every motion shall be accompanied by a concise brief or a list of authorities upon which movant relies. Unless the court directs otherwise, neither a brief nor a list of authorities shall be required with respect to any of the following motions:

d. If the motion does not comply with the requirements of b and c above, the motion may be denied without a hearing, and if a responsive pleading is required, the moving party shall serve any pertinent responsive pleading within twenty (20) days after notice of the court's action. Motions not requiring briefs shall state whether opposing parties agree or object to the request and shall be accompanied by a proposed order granting the relief requested. If there are no opposing parties, or if they cannot be reached, the movant shall so state with particularity. The proposed order shall be served together with the motion upon all parties in the matter. Objections to motions not requiring briefs shall be served and filed within fifteen (15) days after service of the motion or the motion may be deemed confessed.

e. Any party opposing a motion, except those enumerated in Section c above, shall serve and file a brief or a list of authorities in opposition within fifteen (15) days after service of the motion, or the motion may be deemed confessed.

f. If the grounds supporting a motion are not presented for hearing when called, the court, in its discretion, may continue the hearing or rule on the motion or the motion may be denied as having been withdrawn or abandoned. Where a party consents to the denial of his motion, the motion shall be deemed to have been withdrawn. Motions that are not contested may be disposed of by the announcement of one party without the necessity of all counsel appearing.

Where a motion is denied for failure to present or is deemed to have been withdrawn or abandoned, the party asserting the motion waives the objection, and if a responsive pleading is required, the moving party shall be required to serve it within twenty (20) days after notice of the court's action.

The ruling of the court on a motion shall be memorialized by an order prepared by the moving party, or as directed by the court, and shall be filed in the case.

g. Except with the permission of the court after good cause has been shown, a party cannot present any defect or deficiency at the hearing on his motion which was not specifically stated therein, but if the court permits other grounds to be presented, the motion shall be amended in writing, by interlineation if possible, to include the new grounds. Interlineations accomplished pursuant to this Rule upon electronically filed motions shall be memorialized on a copy of the motion which is filed separately with the clerk. This subdivision is not applicable to hearings on new trial motions which are subject to Rule 17.

h. Motions may be decided by the court without a hearing, and where this is done, the court shall notify the parties of its ruling in writing by mail or email.

i. The denial of a motion to dismiss for failure to state a claim upon which relief can be granted, or of a motion to strike a defense because it is insufficient, or of a motion for a summary judgment, or of a motion for a summary disposition of issues will not be reviewed on appeal after the action has been tried on its merits.

j. Joint motions shall be deemed to be joint and several as to all counts in the prior pleading and as to all parties joining in the motion, and where proper grounds are presented to the court, the court must rule on the sufficiency of each claim or defense as to each party.

k. A negative pregnant or a conjunctive denial is not a ground for objecting to the sufficiency of a defense, but the issues raised shall be determined at the pretrial conference.

l. Motions for judgment on the pleadings, motions for a more definite statement, motions to strike redundant, immaterial, impertinent, scandalous or similar matter from a pleading, and objections to the introduction of evidence that are made at the commencement of a trial to test the sufficiency of the pleadings shall not be made. If such motions or objections are made, the court shall summarily deny them without a hearing, and the making of such motions or objections shall not extend the time to serve or file a responsive pleading or take other required action.

m. Appeals from orders granting judgment on motion for summary judgment or summary disposition or dismissal on motion to dismiss for failure to state a claim or for lack of jurisdiction will be subject to accelerated appellate review under Rule 1.36 of the Oklahoma Supreme Court Rules. The record on appeal will be limited to: