Motions for summary judgment and
responses must comply with Local Rule 56.1, as well as the procedures outlined
here.
The statements of undisputed material
facts 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. Parties must make the supporting evidence easy to
find.
Courtesy copies of exhibits to summary
judgment motions and responses, if required (see the “Courtesy Copies” section
of Judge Kness’s webpage), should be tabbed for easy access.
The Local Rules are not mere
technicalities. The Court expects strict compliance with the Local Rules
regarding 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 movant shall not file more than 80
statements of undisputed material facts without prior leave of Court. The
respondent shall be limited to 40 statements of undisputed material facts
absent prior leave of Court. In complex cases, the Court may request that
the parties submit a timeline of events in addition to statements of undisputed
material facts.
Motions to strike are
disfavored. (See the Court’s separate standing order on motions to
strike.) If a party contends that another party has included inadmissible
evidence, improper argument, or other objectionable material in a Local Rule
56.1 submission, the party typically should raise its argument that the Court
should not consider such material in the party’s response or reply brief, not
in a separate motion to strike.