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Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b). 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.

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.