“In the motion for summary judgment, the movant must expressly present the grounds upon which the motion is made. A ‘ground’ is a reason the movant is entitled to judgment and is not presented by mere reference to the summary judgment evidence. The nonmovant need not object to a summary judgment motion that presents no grounds because such a motion is insufficient as a matter of law.” Funmilayo v. Aresco, L.P., No. 05-20-00492-CV (Nov. 30, 2021) (mem. op.) (citations omitted).

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