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Summary Judgment Motions

Motions for summary judgment and responses must comply with Local Rule 56.1.  The court expects strict compliance with the Local Rules on summary judgment.  Failure to comply with the Local Rules may result in the court striking briefs, disregarding statements of fact, deeming statements of fact admitted, and denying summary judgment.  See Modrowski v. Pigatto, 712 F.3d 1166, 1169 (7th Cir. 2013); Keeton v. Morningstar, Inc., 667 F.3d 877, 884 (7th Cir. 2012). 

The statements of undisputed material fact and 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.  Courtesy copies of exhibits to summary judgment motions should be tabbed for easy access.  In complex cases, the court may request that the parties submit a timeline of events in addition to the statements of undisputed material fact.

PLEASE NOTE:  If a party contends that its opponent has included inadmissible evidence, improper argument, or other objectionable material in a Local Rule 56.1 submission, the party typically should raise in its response or reply brief (and not in a separate motion to strike) its argument that the court should not consider such material.

If cross-motions for summary judgment are to be filed, the following briefing schedule will apply unless otherwise ordered.  Defendant's summary judgment motion will be due on the dispositive motion filing deadline.  Plaintiff's combined cross-motion and response to defendant's motion shall be due four (4) weeks thereafter.  Defendant's combined reply in support of its motion and response to plaintiff's cross-motion shall be due four (4) weeks thereafter.  Plaintiff's reply in support of its cross-motion shall be due two (2) weeks thereafter.   Each successive due date shall be measured from the date of the previous filing.  Ruling will be electronic.  Failure to coordinate and/or adhere to these instructions may result in striking of motions. 
 


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