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 requested (see the “Courtesy Copies” section in the links on this Court’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.
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.
Parties submitting deposition testimony in support of or in opposition to summary judgment motions are to provide a cover sheet to the deposition stating (a) the name of the witness, (b) the date of the deposition, and (c) 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 are to provide the Court with the entire transcript of the deposition testimony submitted in support of their respective positions, preferably in the condensed transcript format where multiple deposition transcript pages are reduced to one page.
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.
Parties must include a table of contents for any exhibits.
Parties must use a user-friendly citation format, so that it is easy for the Court to locate any exhibits cited in the briefs.