Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b), as well as the procedures outlined herein. All statements of undisputed material facts and their responses shall be filed separately from the memoranda of law and shall include the line, paragraph, or page number where the supporting material may be found in the record.

The Local Rules are not mere technicalities. Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, and denying summary judgment. See Cracco v. Vitran Exp., Inc., 559 F.3d 625, 632 (7th Cir. 2009).

The movant shall not file more than 80 statements of undisputed material facts without prior leave of the Court. The respondent shall be limited to 40 statements of undisputed material facts without prior leave of the Court. In complex cases, the Court might request that the parties submit a timeline of events in addition to the statements of undisputed material facts.

Please read the Court's Case Management Procedures on "Motions to Strike Strongly Disfavored." This Court's general rule against such motions applies whole-heartedly to summary-judgment briefing and Local Rule 56.1 statements.

With regard to CM/ECF filing, for any word-processed filing (e.g., briefs and memoranda), counsel shall convert the document into a .pdf document by printing or publishing to .pdf, rather than manually scanning a paper copy into .pdf, in order to generate searchable optical character recognition (OCR) text. For any filing of any kind (including exhibits in support of a motion or any Local Rule 56.1 Statement), counsel must run an OCR conversion on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text Recognition, In This File, and select All Pages. If you see the message, “Acrobat could not perform recognition (OCR) on this page because this page contains renderable text,” click “Ignore future errors in this document,” and click OK.

No Early Summary Judgment Motions. If a party wishes to file a summary judgment motion before the close of all discovery (fact and expert), then the party must move for permission to do so. More often than not, either Civil Rule 56(d) applies (so the non-movant is entitled to more discovery) or, even if discovery on a specific issue is complete, it is much more efficient to consider all summary judgment issues at the end of all discovery. The motion for permission must explain why it is sensible to proceed with summary judgment mid-discovery. Also, the proponent should consider that it is almost always wasteful to have two rounds of summary judgment, that is, one round after fact discovery and a second after expert discovery.