The Court requires strict compliance with Rule 56.1(e)(2) which provides in part as follows: "Motions to strike all or portions of an opposing party’s LR 56.1 submission are disfavored. If a party contends that its opponent has included objectionable or immaterial evidence or argument in a LR 56.1 submission, the party’s argument that the offending material should not be considered should be included in its response or reply brief. In the event that the objection is overruled, the failure to admit or dispute an asserted fact may constitute a waiver."

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. 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.  The parties are to include only the relevant portions of any deposition cited to, including 2 pages before  and 2 pages after the cite.

Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, or denying summary judgment. The movant shall not file more than 80 statements of undisputed material fact without prior leave of Court. The respondent shall be limited to 40 statements of undisputed material fact absent prior leave of the Court. In complex cases, the Court may request that the parties submit a timeline of events in addition to the statements of undisputed material fact.

The Court strongly encourages all filings to include hyperlinks to any cases or docket entries referred to in the pleadings.  If possible, the Court prefers hyperlinks to exhibits as well but recognizes that this may entail more time and expense.  To the extent possible, the Court prefers any citation to exhibits, cases, and docket entries to be hyperlinked. 

Please see

 http://www.ned.uscourts.gov/internetDocs/cmecf/hyperlinking_attorneys_word.pdf

for directions on how to include hyperlinks in filings.