Does anyone have a motion for summary judgment on a bill of review that I could borrow from?

Petitioner alleges he did not receive service on the order of default judgment. The clerk admittedly sent the notice to his pre-incarceration residential address instead of his post-incarceration TDCJ address, but remedied this by providing him a copy upon request in 2010. His 30 days for notice of appeal should run from the date he was adequately served, right? Rather than filing notice of appeal, he has been filing motions to compel yadda yadda yadda.

Any form stuff would be appreciated!

I have an answer alleging laches as an affirmative defense. Interested? Email me your email address.