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 Buttron v. Sheehan, No. 00 C 4451, 2003 WL 21801222 (N. D. Ill. Aug. 4, 2003).

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 may request that the parties submit a timeline of events in addition to the statements of undisputed material facts.

Judge Lee disfavors motions to strike all or portions of an opposing party's Local Rule 56.1 submission. Under ordinary circumstances, if a party contends that its opponent has included inadmissible evidence, improper argument, or other objectionable material in a Rule 56.1 submission, the party's argument that the offending material should not be considered should be included in its response or reply brief, not in a separate motion to strike.