What is the outline for a motion for summary judgment/memorandum for this case?

You are employed by the firm of Smith, Henry & Collins L.L.P. You work primarily for the ten-lawyer litigation division of the firm, whose one and only client is Sears.The relationship between Sears and the firm is through a senior partner named R. B. Cyre, who knew Seth Williams when he started the business. R.B. is seldom seen around the firm due to his status as a rainmaker. Keeping Sears happy is a primary concern for your division. Sears is self-insured as a "big box" retailer with thousands of stores. Risk management is handled by a wholly owned subsidiary corporation called Clam Management Inc. in Bensonville Arizona. The adjusters and claims managers who direct the litigation are located there, and communications are conducted through email and telephone. The attitude of Sears toward injury claims in its stores is straightforward: we never settle, and if you want our money, you will have to come and get it. Your supervising attorney and his associate have been defending a lawsuit against one of its stores in Griffin, Illinois. The plaintiff is a 66-year-old gentleman named Stephen Rande, who was injured in a fall at the store, breaking the greater trochanter in his right hip, requiring hip replacement surgery. He also suffered a nasty break to his right wrist that necessitated additional surgery. His medical expenses as of this date exceed $500,000.00, with more to come. His deposition has been taken, and he is likable and believable and will make a perfect witness on his behalf. The depositions of store employees and the store manager have also been taken, and the discovery phase has shifted to medical testimony about Mr. Rande's injuries. Before entering this expensive discovery phase, the adjuster and claims manager have conducted a conference telephone meeting with the litigation team, and a mutual decision has been reached to file a motion for summary judgment to end the litigation now. Your boss, Harley Davidson, assigns you to draft the motion and a memorandum of law supporting the motion for his review. The facts of the case are as follows: On May 1, 2021, the plaintiff, in the company of his six-year-old grandson and sixteen-year-old great-nephew, went to Sears to purchase some goods. As they approached the main entrance to the store, the plaintiff noticed that the gate to the garden center was open. Rather than continuing to the main entrance, he decided to enter the store through the garden center, which was much closer. After he entered the garden center and proceeded about ten feet, he slipped and fell on snow and ice, which caused his injuries. The garden center is open to the public between May 1st and September 1st. but is inaccessible to customers during the winter months. At the time of the plaintiff's fall, two Sears employees, Fred Fury, and Hal Berrger, had been assisting a customer with a propane tank and, as a result, had left the gate to the garden center open. You have a report from the weather bureau documenting a three-inch snowfall the previous evening, which had accumulated in the garden center on top of ice from previous freezes and thaws. It is undisputed that the garden center was not open at the time of Stepen's fall. The plaintiff has filed a one-count complaint against the store with the following allegations, which lay out his theory of recovery: 4. That at all times material hereto, as a retail establishment, it was the duty of the defendant" SEARS, INC." to keep its entrances free and clear of snow and ice to avoid injuries to its customers, including the plaintiff" STEPHEN RANDE" 5. That notwithstanding the above and preceding duty, the defendant was guilty of one or more of the following acts, omissions, and breaches of said duty: a. Failed to keep its entrances clear of ice and snow. b. Failed to properly warn its customers, including the plaintiff, of the presence of ice and snow at its entrances. c. Was otherwise negligent in the maintenance and management of its property. The depositions of employees Fury and Berrger have established that there have been no attempts to remove the snow and ice from the garden center because it is closed. Further, the testimony of the store manager, Willa Weasel, has established beyond doubt that nothing in the design or construction of the garden center has contributed to the accumulation of ice and snow. The store has let the snow lay where it fell, and there are no gutters or downspouts that drain into this part of the property, so it is clear that this is a natural accumulation of ice and snow. Mr. Weasel also testified that the store had a main entrance some 100 feet further north from the open garden center at the time of the plaintiff's fall. This entrance has a heated sidewalk and is kept shoveled and dry during winter. Weasel further testifies that there was a three-inch snowfall the prior evening and that the main entrance was obvious at the time of the plaintiff's fall. The supervising attorney has tasked you with drafting a motion for summary judgment. The issue is whether the store had a duty to keep the garden center free of snow and ice when it was essentially closed, particularly when there was a dry and clear main entrance some 100 feet away. Issues as to the credibility of employees Fury and Berrger, who will no doubt get hammered if there is a big recovery against the store, and the manager, whose annual bonus is diminished by a percentage of any money spent compensating customers who are injured in the store, is not admissible evidence in a motion for summary judgment. You must work with those undisputed facts and demonstrate that the law entitles you to judgment as a matter of law. Your research has uncovered the following cases: In Illinois, a landowner is not liable for the natural accumulation of ice and snow on his/her property. Fillp v. Midlane Airlines, 261 Ill. App. 3d 237 (1st Dist. 1982) To recover for a slip and fall on ice, a plaintiff must show that the ice upon which she fell was an unnatural accumulation caused or aggravated by some action of the defendant. Brand v. R.L. Investment, Inc. 196 Ill. App. 3d 108 (2nd Dist. 1996) For a defendant to be liable for negligence, a plaintiff must establish that the defendant had a duty toward the plaintiff, that he breached that duty, and that the breach was a proximate cause of the plaintiff's injury. Maeon v. Ash Exploration, Inc. 965 F.2d 142 (7th Cir, 1992) A business must provide a reasonably safe means of ingress and egress from their places of business, and this duty is not abolished by the presence of an unnatural accumulation of ice and snow or water Mclean v. Rock Country Club, 352 Ill. App. 3d 229 (2nd Dist. 2014) This exception applies when the evidence shows that the plaintiff was using the "required," "prescribed," or usual means of ingress and egress. John v. Abb Labs, 238 Ill. 2d. 264 (2012) A landowner must only warn its invitees of those conditions or dangers that are either concealed or not obvious to a reasonable customer. Lei v. Jone, 214 Ill. App. 3d 348 (2nd Dist. 2004)