(a) Supporting Suggestions. A party moving for summary judgment must begin its
supporting suggestions with a concise statement of uncontroverted material facts.
Each fact must be set forth in a separately numbered paragraph and supported in
accordance with Fed. R. Civ. P. 56(c).
(b) Opposing Suggestions.
1. A party opposing a motion for summary judgment must begin its opposing
suggestions by admitting or controverting each separately numbered
paragraph in the movant’s statement of facts. If the opposing party controverts
a given fact, it must properly support its denial in accordance with Fed. R. Civ.
P. 56(c). Unless specifically controverted by the opposing party, all facts set
forth in the statement of the movant are deemed admitted for the purpose of
summary judgment.
2. If the opposing party relies on any facts not contained in the movant’s
suggestions, the party must add a concise listing of material facts. Each fact in
dispute must be set forth in a separately numbered paragraph and properly
supported in accordance with Fed. R. Civ. P. 56(c).
(c) Reply Suggestions. The party moving for summary judgment may file reply
suggestions. In those suggestions, the party must respond to the non-moving party’s
statement of additional facts in the manner prescribed in Rule 56.1(b)(1). Unless
specifically controverted by the moving party, all facts set forth in the statement of
the opposing party are deemed admitted for the purpose of summary judgment.
(d) Presentation of Factual Matter. If a party’s suggestions refer to facts contained in
another document, such as a deposition, interrogatory answer, or admission, the party
must attach a copy of the relevant excerpt.
