Meet and Confer Requirement  

With respect to any motions for summary judgment, the Court requires the moving party to advise the opposing party in a short letter (e.g., 2-3 pages) of the basis for the motion (including relevant legal authority). Do not file the letter with the Court. The Court requires the moving party and the opposing party to then meet and confer via telephone, video, or in-person conference, during which time the opposing party should advise the moving party of the specific factual matter(s) or legal authority that it believes would defeat the motion. After this consultation, which is intended to promote efficiency, if the movant still wishes to file the motion, the movant should do so and the Court will rule on the motion. Any motion must state with specificity what the parties did to comply with the meet and confer requirement.

If the non-moving party is a pro se litigant, the moving party must provide the pro se litigant with the notice provided in Local Rule 56.2 at the time it provides the non-moving party with its letter outlining the basis for the summary judgment motion. 

Motions for Summary Judgment

Motions for summary judgment and responses must strictly comply with Local Rules 56.1, as well as the requirements outlined herein.

Summary Judgment Deposition Testimony Evidence

Parties submitting deposition testimony in support of or in opposition to summary judgment motions are to provide a cover sheet to the deposition stating the name of the witness, the date of the deposition, and the deponent’s title and/or role in, or relationship to, the pending litigation (e.g., "John Doe, plaintiff's human resources manager" or "Jane Doe, plaintiff's union representative"). Also, parties should not just provide excerpts of deposition testimony, but should provide the Court with the complete deposition transcript for any deposition cited, preferably in the condensed transcript format.

Courtesy copies

Within a week of filing, parties shall deliver to the Court copies of their summary judgment memoranda, Local Rule 56.1 statements, and supporting exhibits organized in binders (three ring or bound) with labeled tabs for the Court’s ease of reference.