I'm defendant in a civil contract case that's been stuck a long time going nowhere. Neither side has initiated discovery. I'd like to move out of state later this year and would like this put to rest. I categorically deny plaintiff's claim. Plaintiff last filed a motion for summary judgment to which I objected and motioned for denial with memorandum in support. I had answered the complaint previously so don't think I can motion to dismiss. There are disputed facts which appear to preclude summary judgment. Can I motion for judgment on the pleadings at this stage? If so, do the pleadings stay closed until the hearing or will the plaintiff be able to file additional things? Thanks.