Judge Gregory R. Werner

The responding party has three business days to file a response, with the same restrictions.

containing (1) a certificate of conferral and (2) a brief which shall not exceed three pages, double spaced, with 12-point font

These page limitations shall include the motion for summary judgment, caption/cover page, statement of facts, procedural history, argument, closing, signature block, and all other matters, except the certificate of service.

If a party elects to file more than one rule 56 motion, then the motions and response briefs shall not exceed 25 pages total for all such motions (not each such motion) filed by that party.

Motions and response briefs shall not exceed 20 pages, double spaced. Reply briefs shall not exceed 15 pages, double spaced.

The body of the text shall be no smaller than 12-point type.

Footnotes are not permitted.

Should a discovery dispute arise, the complaining party shall file a Notice of Discovery Dispute, containing (1) a certificate of conferral and (2) a brief which shall not exceed three pages, double spaced, with 12-point font, explaining the exact nature of the dispute, the relief requested, and any supporting legal authority.

No later than 42 days after the case is at issue as defined by Rule 16(b)(1), the parties shall file a proposed case management order that complies with the requirements of Rule 16.

In a section of the brief styled “Statement of Undisputed Material Facts,” the movant shall set forth in simple, declarative sentences, separately numbered and paragraphed, each material fact which the movement believes is not in dispute and which supports movant’s claim that movant is entitled to judgment as a matter of law.

each separately numbered and paragraphed fact must be accompanied by a specific reference to material in the record which establishes that fact. General references to pleadings, depositions, or documents are insufficient if the document is over one page in length.

Because of the voluminous factual materials which are frequently submitted with a motion for summary judgment, all Rule 56 motions must comply with the following requirements:

any reply brief must comply with the following requirements:

in the case of other materials not numbered by paragraph, line or page, a reference which will enable the court to ascertain the fact without reviewing the entire document; the effort at specificity may be made by highlighting, manual underscoring, or pagination supplemented by the movant.

Any party opposing the motion for summary judgment shall, in a section styled “Response to Statement of Undisputed Material Facts,” admit or deny the asserted material facts set forth by movant.

in a separate section styled “Reply Concerning Undisputed Facts,” include any factual reply which movant cares to make regarding the facts asserted in its motion to be undisputed, supported by specific references to material in

The admission or denial shall be made in separate paragraphs numbered to correspond to movements paragraph numbering.

in the case of materials filed with the court, the title of the document, the date on which it was filed or served, and a specific paragraph or page and line numbers; or, if the document is attached to the motion, the paragraph or page and line number;

Each separately numbered and paragraphed fact shall be accompanied by a specific reference to material in the record which establishes the fact or least demonstrates that it is disputed.

in the case of affidavits submitted in support of the motion, the specific paragraph number establishing the fact;

in the case of depositions or other documents bearing line numbers, the specific page and line(s) establishing the fact;

Any denial shall be accompanied by a brief factual explanation of the reason(s) for the denial and a specific reference to material in the record supporting the denial.

If the party opposing the motion believes that there exist additional disputed questions of fact which it has not adequately addressed in the submission it has made pursuant to subparagraph 4 above (for example, disputed facts concerning an affirmative defense), the party shall, in a separate section of the party’s brief styled “Statement of Additional Disputed Facts,” set forth in simple, declarative sentences, separately numbered and paragraphed, each additional, material disputed fact which undercuts movant’s claim that it is entitled to judgment as a matter of law.

in the case of interrogatories or requests for admission (the pertinent parts of which must be filed with the motion), the number of the interrogatory or request;

In a separate section styled “Response Concerning Disputed Facts” (with respect to each fact which the opposing party, pursuant to subparagraph 5 above, claims to be in dispute), either admit that the fact is disputed or supply a brief factual explanation for its position that the fact is undisputed, accompanied by a specific reference to material in the record which establishes that the fact is undisputed.