M.D. La. LR 56

(a) Motions for Summary Judgment. In addition to the material required to be filed by Local Civil

Rule 7(d), (f), & (g), a motion for summary judgment and opposition thereto shall comply with

the requirements of this rule.

(b) Supporting Statement of Material Facts.

(1) A motion for summary judgment shall be supported by a separate, short, and concise

statement of material facts, each set forth in separately numbered paragraphs, as to which

the moving party contends there is no genuine issue of material fact to be tried. Each fact

asserted in the statement shall be simply and directly stated in narrative without footnotes

or tables and shall be supported by a record citation as required by subsection (f) of this

rule.

(2) Nothing in this Local Civil Rule 56 precludes the parties from filing a stipulated statement

of material facts as to all, or some, of the facts underlying a motion for summary judgment,

or any opposition thereto. In the event the parties file a stipulated statement of material

facts, such stipulated facts shall control and take precedence over any conflicting

statement of fact filed by any party to the stipulation.

(c) Opposing Statement of Material Facts. A party opposing a motion for summary judgment

shall submit with its opposition a separate, short, and concise statement of material facts. The

opposing statement shall admit, deny or qualify the facts by reference to each numbered

paragraph of the moving party’s statement of material facts and unless a fact is admitted, shall

support each denial or qualification by a record citation as required by this rule. Each such

statement shall begin with the designation “Admitted,” “Denied,” or “Qualified” and, in the case

of an admission, shall end with such designation. The opposing statement may contain in a

separately titled section additional facts, each set forth in a separately numbered paragraph and

supported by a record citation as required by subsection (f) of this rule.

(d) Reply Statement of Material Facts. A party replying to the opposition to a motion for summary

judgment shall submit with its reply a separate, short, and concise statement of material facts

which shall be limited to any additional facts submitted by the opposing party. The reply

statement shall admit, deny or qualify such additional facts by reference to the numbered

paragraphs of the opposing party’s statement of material facts and unless a fact is admitted,

shall support each denial or qualification by a record citation as required by subsection (f) of this

rule. Each such reply statement shall begin with the designation “Admitted,” “Denied,” or

“Qualified” and, in the case of an admission, shall end with such designation.

(e) Motions to Strike Not Allowed. Motions to strike statements of fact are not allowed. If a party

contends that an individual statement of fact should not be considered by the court, the party

may include as part of the response that the statement of fact “should be stricken” with a brief

statement of the reason(s) and the authority or record citation in support. Without prejudice to

the determination of the request to strike, the party shall admit, deny or qualify the statement as

provided in this rule. A party may respond to a request to strike either in the reply statement of

material facts as provided in this rule or, if the request was made in a reply statement of material

facts, by filing a response within 14 days of service of the reply statement. A response to a

request to strike shall be strictly limited to a brief statement of the reason(s) why the statement

of fact should be considered and the authority or record citation in support.

(f) Statement of Facts Deemed Admitted Unless Properly Controverted; Specific Record of

Citations Required. Facts contained in a supporting or opposing statement of material facts,

if supported by record citations as required by this rule, shall be deemed admitted unless

properly controverted. An assertion of fact set forth in a statement of material facts shall be

followed by a citation to the specific page or paragraph of identified record material supporting

the assertion. The court may disregard any statement of fact not supported by a specific citation

to record material properly considered on summary judgment. The court shall have no

independent duty to search or consider any part of the record not specifically referenced in the

parties’ separate statement of facts.

(g) Facts Admitted for Purpose of Summary Judgment. Facts deemed admitted solely for

purposes of summary judgment shall not be deemed admitted for purposes other than

determining whether summary judgment is appropriate.

(h) Number of Motions for Summary Judgment. As a general rule, a party may file only one

motion for summary judgment that addresses all issues for which that party seeks summary

judgment. A party may submit multiple motions for summary judgment only after seeking leave

of Court and demonstrating good cause.