The Court requires strict compliance with Local Rule 56.1 in the briefing of all summary judgment motions. Any party moving for summary judgment against a party proceeding pro se must also comply with Local Rule 56.2. In addition, to assist the Court in reviewing the factual record submitted in connection with summary judgment motions, the Court requires the following:

A courtesy copy of the memorandum of law, depositions, and other materials relied upon in support of the motion (as required by Local Rule 56.1(a)(1)-(3)) or in opposition of the motion (as required by Local Rule 56.1(b)(1)-(3)) must be delivered to Judge Iasparro’s operations specialist in the Clerk’s Office, Room 2200, within one business day of filing. The courtesy copy of the compendium must be securely bound, must separately tab each document, and must contain an index identifying what document is contained under each tab. It must also have the CM/ECF header.

All statements of undisputed material facts offered by the moving party under Local Rule 56.1(a)(3), or statements of additional facts offered by the opposing party under Local Rule 56.1(b)(3)(C), must list the facts in short, numbered paragraphs that refrain from argument. Argument must be reserved for the parties’ memorandum of law. Each numbered fact statement must contain a specific citation to affidavits, depositions, or other materials that support the fact statement, as well as a specific citation to the tab(s) in the compendium where those materials may be found. Failure to provide support for a statement of fact may result in that alleged “fact” being disregarded. See Friend v. Valley View Community Unit School Dist. 365U, 789 F.3d 707, 710–11 (7th Cir. 2015).

All responses to statements of undisputed material facts offered by the opposing party under Local Rule 56.1(b)(3)(B), or responses to statements of additional facts offered by the moving party under Local Rule 56.1(a), shall be in a format similar to that used in answering a complaint: that is, the response must repeat each numbered paragraph of the fact statement, and then immediately following each numbered statement must state whether the alleged fact is “undisputed” or “disputed.” As with the fact statements submitted under Local Rules 56.1(a)(3) and 56.1(b)(3)(C), the responses to those fact statements must refrain from argument. The significance or lack of significance of a disputed or undisputed fact may be argued in the respondent’s legal memorandum. If a particular fact is undisputed, nothing more should be said in the response. If a particular fact assertion is disputed in whole or in part, the response must state what part of the assertion is disputed and must contain a specific citation to the supporting affidavits, depositions, or other materials as well as a specific citation to the tab(s) in the compendium where those materials may be found. Failure to provide support for an alleged fact dispute may result in that fact being deemed admitted. See Curtis v. Costco Wholesale Corp., 807 F.3d 215, 218-19 (7th Cir. 2015).

In accordance with Local Rule 56.1, absent prior leave of Court, a movant shall not file more than 80 separately numbered statements of undisputed material fact, and a party opposing a summary judgment motion shall not file more than 40 separately numbered statements of additional fact under Local Rule 56.1(b)(3)(C). The Court reminds parties that the fact statements under Local Rule 56.1(a)(3) and Local Rule 56.1(b)(3)(C) “shall consist of short numbered paragraphs.”

Motions to strike and motions to deem facts admitted will not be accepted by the Court. These concerns should be raised in the parties’ briefs or in their responsive Local Rule 56.1 statements.