You should likely file two separate pleadings.
You need to respond to the specific issues raised in the Motion to Dismiss. Often, a response to a Motion to dismiss should include a Motion for Leave to Amend your Complaint to remedy any deficiencies raised by the Motion. The Motion to Amend should include a copy of the proposed Amended Complaint.
The Motion for Summary Judgment must be supported by admissible evidence. It is often not wise to file such a Motion too early in your case as it can be defeated by a simple affidavit. There are other tactical issues to consider on the timing of your motion. You should at least consult with an attorney. Good luck!
This information is not legal advice. It is for general knowledge purposes only and cannot be relied on as legal advice. It is not appropriate to rely on information that is based upon insufficient facts. Asking the right questions and obtaining the needed information is a critical part of any attorney's advice. Information provided by this attorney is not a substitute for legal advice and the information provided should not be the basis for making an important decision.
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